FROM THE LEGITIMATE INTEREST OF THE TAXPAYER TO THE SUBJECTIVE RIGHT: GENESIS AND EVOLUTION

The subject of the study is a little-studied in the theory of tax law issue related to the evolution of the taxpayer's permits. The study analyzes the process of transformation of legitimate interest into the subjective right of the taxpayer. On the basis of a retrospective analysis of tax legislation systematized knowledge of the dialectic of this transformation. The article considers the actual basis of the transition of the taxpayer's legitimate interest to the prompt return of value added tax (VAT) to the subjective right to apply the application procedure for VAT refund. The author substantiates the idea that the main objective reason for the transformation is the complexity of social and economic relations. It is concluded that the consequence of formalization of legitimate interest in subjective law is the acquisition of a more stable legal status and the transition to a qualitatively new, more secure level of permission. As a feature of the newly transformed law, its normative saturation is noted both in the content and in the details of its implementation.