NEW TAXATION DIVISION GOES AFTER SYSTEMIC ERRORS THE TAXATION DIVISION’S FIELD OF ACTIVITY A natural focus of an Ombudsman institution in the detection of systemic errors will be whether the tax authorities observe the general provisions and principles within administrative law – for example whether the authorities have investigated a case sufficiently or whether the citizen has been informed about the grounds in a way that he or she can understand. These are quite basic fundamental rules aimed at protecting the citizens’ legal rights. That is also the reason why especially such questions and investigations have been given priority by the Taxation Division in 2017 and will continue to be given priority in the future. However, this does not mean that the Taxation Division cannot consider material tax questions – meaning the outcome of a tax case as such – and such questions have also been the subject of a number of cases considered in 2017. EXTERNAL ACTORS CAN PUT US ON THE RIGHT TRACK One of the big tasks for the Taxation Division is to find out how to detect systemic errors. Obviously, we need focus points from the outset to even know what to look for. Sometimes, media coverage can put the Ombudsman on the right track. On other occasions, concrete complaint cases indicate issues of a more general nature. But also input from external actors can be most useful in this context, as the Taxation Division has learned a number of times. For instance, external actors – such as expert committees for tax lawyers and auditors – have in a number of cases pointed out some tax authority-related issues which they see as problematic. This means that the Taxation Division gains insight into what these actors – who between them have numerous con­ tacts to the tax authorities and know the system well from a user’s point of view – experience as actual procedural problems. 15