SAFE TAXPAYER OR SECURED FISCAL INTEREST OF THE STATE IN THE LIGHT OF THE CONDITIONAL INDIVIDUAL INTERPRETATION

Analyzing accepted in Tax Law provisions solutions we can formulate that tax administration was equipped in such institutional solutions which are submitted to implement the fiscal goal. Thus, in confrontation with fiscal interest of the state, the taxpayer' s interest may suffer prejudice. This fact upgrades unusual, important question of the relevant guarantees which protect taxpayer's rights. This circumstance is particularly meaningful while we take into account tax law fluctuation. Frequent tax law provisions amendments constitute denial of the Montesquieu idea "to judge today as it will be judged tomorrow", they lead to lower so called "availability of law" referring to the norms addressee. Taking it into account, the article analyzes the tax law interpretation. institution.. On the background of the accepted solutions, the analyzed institution may be treated as sui genois expectation of the tax organ reaction. It is worth to indicate therefore, that protection and guarantee functions of the individual interpretation is performed at the moment while, acting in confidence to the tax organ, which issued interpretation of specified activities and conducts which purpose, indication, subject, are determined by the content of the issued interpretation, we undertake particular activities.