Summary

The activity of a tax collector in the collection of taxes is a specific type of administrative proceeding. Since administrative proceedings always involve inequality of parties, special attention should be paid to the protection of the rights of a weaker party (the taxpayer, in this case) in legal regulation.
The author analyses the principles adopted by the German tax law in the protection of the rights of taxpayers in comparison with the corresponding provision in Estonian legislation. The author reaches the conclusion that the Estonian law does not provide taxpayers with guarantees similar to those prescribed by the German law. In Estonia, the activities of tax collectors are regulated by internal regulations. Consequently, an important source of Estonian tax law is custom which, from the viewpoint of the rule of law, is inadmissible.