METHODS OF RESOLVING TAX DISPUTES: A COMPARATIVE LEGAL ANALYSIS OF UZBEKISTAN, GERMANY, THE UNITED STATES, RUSSIA, AND CHINA

Abstract

This article examines the methods of resolving tax disputes in the Republic of Uzbekistan within a broad comparative legal framework encompassing Germany, the United States, Russia, and China. The study proceeds from the constitutional premise that the state bears primary responsibility for the protection of individual rights and freedoms, including in the domain of tax relations. Drawing on the legislative frameworks and administrative practices of the jurisdictions under review, the article analyses the two principal categories of dispute resolution -- pre-trial (administrative) and judicial -- and identifies the procedural architecture of each. Special attention is devoted to Uzbekistan's institutional mechanism for pre-trial settlement, including the Department for Pre-trial Settlement of Tax Disputes established under Presidential Decree No. PP-3802 of 2018, the procedural requirements for filing complaints, the grounds for dismissal, and the powers of the reviewing authority. The comparative analysis reveals that while the jurisdictions under review share a common commitment to providing taxpayers with effective administrative remedies before judicial recourse, they differ significantly in the procedural formality of their systems and their use of alternative dispute resolution mechanisms such as mediation. The article concludes that international experience supports the further development of Uzbekistan's pre-trial settlement framework as a means of reducing the burden on courts, improving taxpayer compliance, and strengthening the rule of law in the fiscal domain.