---
title: "Tax Court Litigation"
url: "https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-court-litigation-en"
field: "Dispute Resolution & Litigation"
description: "Tax disputes: appeal within 20 days, Revenue Service, Dispute Resolution Council and court. Legal.ge."
reviewed: "2026-07-09"
updated: "2026-11-07"
publisher: "legal.ge"
---

# Tax Court Litigation

> Source: legal.ge, https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-court-litigation-en

## The Two Arenas: Ministry System or Court

A tax dispute in Georgia may be considered both in the system of the Ministry of Finance of Georgia and in court — this choice is provided by law itself, and Article 296 of the Tax Code establishes the procedure for considering a dispute within the ministry system. The decisive guarantee is that at any stage of a tax dispute within the Ministry of Finance system the complainant has the right to apply to the court. The procedure for conducting a tax dispute in court is determined by the administrative procedural legislation of Georgia.

The practical plan is thus formed: the dispute begins on the administrative arena, but the strategic decision — whether to remain before the Council or move to court — rests in the complainant's hands and may be taken at any point of its course. This flexibility is the complainant's principal procedural advantage: the administrative stage allows the position and the evidence to be refined, while the court route guarantees independent consideration. The choice depends on the complexity of the case, the volume of the liability in dispute and the prospects of administrative practice, and the accuracy of that assessment often predetermines the outcome.

## Dispute-Resolution Organs and the Two-Stage Rule

Within the Ministry of Finance system tax disputes are considered by the Revenue Service and the Dispute Resolution Council at the Ministry of Finance of Georgia. The dispute in the system is two-stage and begins with the submission of a complaint to the Revenue Service; the exception is the preliminary decision — it is no longer appealed to the Revenue Service, and the person has the right to appeal it directly to the Dispute Resolution Council.

The composition of the Dispute Resolution Council is determined by the Government of Georgia, and the dispute-resolution organs have regulations approved by the Government that define the procedure for considering complaints and communicating with complainants. The Council's apparatus ensures the preparation of incoming complaints for consideration, provides complainants with information connected with the proceedings, and formalizes the decisions adopted; by decision of its head the apparatus may also hold a preparatory meeting with the parties to clarify the circumstances of the complaint. For the complainant the preparatory meeting is an additional opportunity: the material circumstances of the dispute can be clarified in advance and the mandatory parts of the position separated out.

The architecture of the administrative stage is thus: the first stage proceeds before the Revenue Service, the second before the Dispute Resolution Council. The exception for preliminary decisions simplifies this scheme — such a decision is no longer considered by the Service and is appealed directly to the Council, which saves time where the subject of the dispute is the foundation of that very decision.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/dispute-resolution-and-litigation-en/tax-court-litigation-en

### Where is a tax dispute considered?

In the Ministry of Finance system — before the Revenue Service and the Dispute Resolution Council — or in court; at any administrative stage an application to the court is possible.

### How long is the appeal deadline?

20 days from delivery of the decision — both for a Revenue Service decision and for a Council decision.

### What follows a missed deadline?

A dispute not continued within the deadline is deemed recognition of the disputed tax liability; proving the violation of the deadline lies on the tax organ.

### How does a dispute begin in the system?

It is two-stage and begins with a complaint to the Revenue Service; a preliminary decision is appealed directly to the Dispute Resolution Council.