CEDH · CASELAW;COMMUNICATEDCASES;ENG — 17 mars 2026

.s800EAC49 { font-size:12pt } .s379BC09C { margin-top:36pt; margin-bottom:0pt; text-align:right } .sBB9EE52A { font-family:Arial } .s32563E28 { margin-top:0pt; margin-bottom:0pt } .s5E1364CA { margin-top:0pt; margin-bottom:12pt; text-align:center; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .s339D85E6 { margin-top:0pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s665E407E { margin-top:66pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s29100277 { font-family:Arial; font-weight:bold } .s10950C61 { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:justify } Published on 7 April 2026   THIRD SECTION Application no. 42708/23 Georgi Mihaylov KALICHKOV against Bulgaria lodged on 1 December 2023 communicated on 17 March 2026 SUBJECT MATTER OF THE CASE The application concerns the amount of adverse costs imposed on the applicant in the course of tax proceedings. Following a tax audit conducted in 2021, the National Revenues Agency ordered the applicant – a natural person operating as a sole trader – to pay more than 3,3 million Bulgarian levs (BGN), the equivalent of more than 1,7   million euros (EUR), in unpaid taxes, together with about BGN   1,1   million (EUR 580,000) in default interest. The applicant sought judicial review. In a judgment of 13 June 2022 the Stara Zagora Administrative Court upheld the tax authority’s order, and directed the applicant to pay adverse costs in the amount of BGN   27,925 (EUR 14,280) for the remuneration of the National Revenues Agency’s in ‑ house legal representatives. Upon appeal, the Supreme Administrative Court upheld the above judgment on 17 May 2023, ordering the applicant to pay the National Revenues Agency an additional BGN 62,743 (EUR 32,000) in adverse costs. In a subsequent decision of 2 August 2023, the Supreme Administrative Court dismissed the applicant’s objection concerning the amount of those costs, rejecting in particular his argument that they were disproportionately high. The applicant complains under Article 1 of Protocol No. 1, relying in addition on Article 13 of the Convention, of the overly high amount of adverse costs imposed on him. He specifically challenges the domestic legal rule – Article   161 of the Code of Fiscal Procedure, as applicable at the material time – under which adverse costs in tax proceedings were calculated as a percentage of the pecuniary interest at stake. QUESTIONS TO THE PARTIES Did the orders for the applicant to pay adverse costs to the National Revenues Agency in the global amount of 46,280 euros (EUR) represent a disproportionate interference with his “possessions” in breach of Article 1 of Protocol No.   1? In particular, was the amount of adverse costs justified in the circumstances of the individual case, and did the national courts impose on the applicant an excessive individual burden?