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Dispute Resolution

Administrative Disputes

When a state authority issues a decision that affects you — a tax assessment, a customs ruling, a refused permit, a municipal order, a regulator's fine — challenging it generally proceeds under the administrative-law procedure rather than ordinary civil litigation. The right forum, the relevant deadline and the effect of appeal on enforcement all depend on the type of act and the applicable special statute. We represent businesses and individuals through the full appeal track — administrative appeal, the competent Administrative Court, and the Supreme Administrative Court (VAS) on cassation.

Who we work with

  • Companies under NAP tax audit or assessment
  • Importers and exporters facing customs decisions
  • Property owners challenging municipal valuations and orders
  • Operators of regulated activity (financial, telecom, energy, gambling, food)
  • Foreign nationals appealing immigration or residence-permit refusals
  • Individuals and companies challenging administrative-penal sanctions (penal decrees, electronic tickets) — typically before the district court at first instance

Tax disputes (NAP)

  • Administrative appeal of revisional acts (РА) and supplementary tax assessments under the Tax-Insurance Procedure Code — filed through the issuing authority to the competent director of the Appeals and Tax-Insurance Practice Directorate within 14 days
  • Appeals against findings on VAT, corporate income tax, personal income tax and social contributions
  • Suspension of enforcement during appeal — not automatic for tax revision acts; we file the separate suspension request with statutory security
  • VAT refund, offsetting and recovery disputes — including unlawful delay or refusal
  • Coordinated work with our Tax Law practice on the underlying merits

Customs and import / export disputes

  • Tariff classification, valuation and origin disputes
  • Customs penalties and security demands
  • Seizures and forfeitures
  • EU Customs Code procedures and refund claims

Municipal acts & permits

  • Construction permits, denials and stop-work orders
  • Property-tax valuations and municipal fees
  • Demolition orders and changes to detailed development plans
  • Trade licences, signage and outdoor-use permissions

Sector regulators & fines

  • FSC (financial services), BNB (banking), CRC (telecom), KZK (Commission on Protection of Competition), KZP (Consumer Protection Commission), KZLD / CPDP (Personal Data Protection Commission)
  • Labour Inspectorate findings and penalties
  • Gambling, food-safety and environmental fines
  • Constitutional and EU-law arguments where applicable

Administrative-penal sanctions issued by these bodies (penal decrees, electronic tickets) ordinarily follow a separate route — first-instance review before the competent district court under the Administrative Violations and Sanctions Act, with cassation before the relevant administrative court.

How the procedure works

The track depends on the type of act and the governing statute. The framework below is the general route under the Administrative Procedure Code (АПК) and the Tax-Insurance Procedure Code (ДОПК) — many sector statutes provide their own variation, and not every act has an administrative-appeal stage.

  • Administrative appeal. Where available or mandatory, the appeal is generally submitted through the issuing authority to the competent superior or specially designated reviewing authority — not the issuing authority itself. For tax revision acts, the appeal goes to the director of the Appeals and Tax-Insurance Practice Directorate. The deadline is often 14 days, but special statutes may set 7, 30 days or one month.
  • Court appeal. If the administrative appeal is rejected, the matter goes to the competent first-instance court — usually the Administrative Court for the relevant district (Sofia City, Sofia Region, regional Administrative Courts), the Supreme Administrative Court as first instance under specific statutes, or the district court for administrative-penal sanctions.
  • Effect of appeal on enforcement. Under the general АПК, a timely challenge to an individual administrative act ordinarily suspends enforcement unless preliminary enforcement has been ordered or a special rule applies. Tax revision acts are a major exception — they are not automatically suspended, and suspension requires a separate request with statutory security. We map this carefully at the start of every matter.
  • Cassation. The first-instance judgment may be appealed to the Supreme Administrative Court (VAS) within the statutory cassation period — generally 14 days, with sector variations.
  • Costs and damages. The successful party may be awarded recoverable procedural costs on request, subject to evidence and proportionality. Damages from the state may be recoverable under the State and Municipal Liability for Damages Act where the statutory conditions are met — typically requiring annulment or declared unlawfulness of the act.

Why early advice is critical

Administrative deadlines are short — frequently 14 days, sometimes 7 — and the appeal route varies sharply by statute. The administrative phase is often the best opportunity to establish the factual record, particularly in tax, customs, licensing and inspection matters. Delayed evidence or incomplete objections can materially weaken the case and, under some special procedures, may limit what can effectively be proved later. The earlier we are involved — ideally during the audit or inspection, not after the decision — the more strategic flexibility you retain.