ADMINISTRATIVE COURTS AND THE RESOLUTION OF TAX DISPUTES: THE FORMATION OF ADMINISTRATIVE JUSTICE IN UZBEKISTAN IN COMPARATIVE PERSPECTIVE

Abstract

This article examines the institutional development of administrative courts in the Republic of Uzbekistan as a mechanism for the judicial resolution of tax disputes and other public law conflicts arising between citizens, legal entities, and state bodies. The study traces the formation of Uzbekistan's administrative justice system from the constitutional amendments of 2017 through the enactment of the Law on Administrative Procedures and the Code of Administrative Proceedings in 2018, to the comprehensive judicial restructuring effected by Presidential Decree No. UP-6034 of 2020 and the Development Strategy of New Uzbekistan for 2022-2026. Drawing on a comparative analysis of three principal models of administrative justice -- the specialised court model (Germany), the general court model (Russia), and the quasi-judicial tribunal model (the United States) -- the article evaluates the choices made by the Uzbek legislature in structuring its administrative courts and assesses the adequacy of those choices for the resolution of tax disputes. The article further examines the procedural competence of Uzbek administrative courts, including their jurisdiction over complaints against decisions of tax authorities, and the forms of application available to citizens and legal entities. The comparative analysis demonstrates that whilst no single model of administrative justice is universally optimal, the establishment of specialised administrative courts with clearly defined competence -- as implemented in Uzbekistan -- represents an institutional advance aligned with European best practice and with the broader constitutional commitment to the rule of law.