Shcherbakovа O. Subject of proof in tax disputes.

The paper reveals the essence, nature and characteristics of the subject of proof in tax disputes. Separate study and subject characteristics amenable to proof alone on the stage of the administrative appeal and judicial tax litigation stage. Found out what facts should include the subject of proof in tax disputes. Based on in-depth scientific analysis determined the main features of proof in tax disputes. Special attention is paid to the stages of tax litigation and its impact in terms of proof. The characteristic of the subject, and of the burden of proof on each of the stages of tax litigation. It presumed that when in doubt the reliability of evidence, the court can initiate their own review. The conclusions and suggestions for improving approaches to forming the object of proof in tax disputes.