Marek Kalinowski
The emergence and development of the concept of the tax legal relation
Summary
The subject matter of the paper is to present the emergence and development of the concept of the tax legal relation. Primarily, the concept of the tax legal relation developed by F. Myrbach-Rheinfeld in the early twentieth century has been described. According to him, this legal relation was a tax debt relationship. It arose when a payment demand was issued and delivered to the taxpayer.
The paper also presents the scientific discussion concerning certain aspects of the tax legal relation which has influenced the final concept of that relation. First of all, a dispute concerning the very nature of that relationship has been presented. Secondly, the author described the dispute concerning the sources and the moment of rise of the tax debt. Finally, the B. Griziotti's idea concerning the cause of tax liabilities (causa impositionis) and the scientific dispute concerning it has been discussed.