<div> <div> <span>Resolving Tax Disputes Under Amhara Regional State Tax Laws, and the Appellate Process</span> </div> </div>

This study carefully examines the appellate process to resolve tax disputes based on the tax laws of the Amhara Region. The researcher identifies systemic injustice and the failure of the law to meet its constitutional obligations. When analysing the appellate process to resolve conflicts of tax dispute, the study considers that Ethiopia operates as a federal-state regime established in the FDRE Constitution recognizing both federal and regional tax powers. While the laws for disbursing tax disputes in the Amhara region follow the federal tax laws, they are criticized for having institutional biases, barriers to process and limited accessibility resulting in disadvantages to taxpayers. The researcher was following a qualitative legal methodology which involved doctrine-based study of the laws and interviewing diverse stakeholders to assess the fairness, timeliness, efficiency, and independence of the appellate bodies. The findings indicate that the appellate process as a three-tiered Review Committee, Tax Appeal Commission and regular courts each has its structural problems to fair tax dispute resolution. Review Committees and TACs were troubled as independent bodies making administrative redress from previous tax authority determinations, as they were influenced by executive bodies being made up of local representatives of the tax authority who they were to decide against. The procedures of the Review Committees and TACs were equally problematic with the requirement to deposit 50-75% tax owing prior to making any appeal tax authority determination, thereby limiting access to appeal and violating FDRE Article 37 right to be free of unreasonable discrimination to tax disputes for poorer taxpayers. Further troubling issues include unreasonable lengthy adjudications of tax appeals, inconsistent rulings, and no expertise of the adjudicators; and a general erosion of reliability by the public. Overall, the process was also constitutionally unsustainable and violated the guarantees of impartial tribunals and reasonable assurance of due process; failing to fulfill international standards and expectations. This study indicates reform in: separating appellate bodies from executive control; lowering financial barriers for appeals through income-contingent thresholds; implementing digitisation; and incorporating alternative dispute resolution (ADR) modes. These reforms could mitigate institutional bias, improve transparency; and comply with constitutional protections in ways that balance rights of taxpayers with obligations arising from revenue administration, contributing to the socio-economic development of the Amhara region. This study also indicates that there is need for reform through legislation and structure that service regional practices against a constitutional framework for tax and global standards.