Tax and Customs Peculiarities applied for the Religious Organizations
- Religious Organizations in Legal Tax Relations
- The Religious Organizations In Legal Relations Related To Customs
- The Procedure to Use Privileges in the Framework of Humanitarian Aid and Charity Programs (Activities) for Religious Organizations
- The Means for the Protection of the Rights
In the Republic of Armenia the religious organizations are fully fledged units for various legal relations, and in this respect tax and customs relations are no exception.
In general, tax and customs general regulations are applied for religious organizations, however for certain cases the state has defined tax and customs peculiarities on legislative level, in purpose to present certain state support to the activities of those organizations.
This article will address the tax and customs relations, the procedures, the issues to be regulated referring to religious organizations, it will also cover the privileges the organizations have, as well as will address the means applied for the supervision of the organizations and its rights protection.
Religious Organizations in Legal Tax Relations
In the Republic of Armenia, the religious organizations are considered to be taxpayers, who like all the other taxpayers are obliged to calculate and pay on their own all the taxes and fees defined by the Tax Code of the Republic of Armenia and by the laws of the Republic of Armenia on fees prescribed for certain cases, procedures and amounts.
The rule of the exclusion of discrimination is defined in the Tax Code, Article 3, Part 1, Clause 4, according to which the application of taxes and fees, and tax administration should not have discriminatory character depending on the social, political, religious, ethnic, ideological as well as other factors defined by the Constitution of the Republic of Armenia.
The above mentioned legal norm makes it clear that the prohibition of discrimination is specified, as a result of which it guarantees that in tax relations the discrimination depending on religious character is also forbidden.
It is worth noting that monetary and other donations received by religious organizations, as well as revenues received from the citizens are not taxable.
Depending on their activities, tax liabilities may arise for religious organizations with the following tax and fee types.
- state taxes – Value added tax (hereinafter VAT), profit tax, income tax, environmental tax,
- local taxes – real estate tax and property tax on vehicles
- state fees – state fee, social payment
local fee – local fee and local payment․
Value Added Tax
In the Tax Code of RA - Article 64, part 2, clauses 7, 9 and 10, it defines those transactions and operations in case of which the religious organizations are exempt from the liability of paying VAT. They are:
- gratuitous supply of goods
- gratuitous performance of works
- gratuitous provision of services
- provision of services related to the organization of religious ceremonies
- alienation of religious attributes to religious organizations
- alienation of these attributes by religious organizations
- import of goods, supply of goods, performance of works and provision of services by religious organizations within the framework of humanitarian aid and charity programs (activity), as well as supply of goods, performance of works and provision of services directly related to and of crucial importance to the implementation of such programs.
In all the other cases not listed above, while performing transactions (operations) defined in the Article 60 of Tax Code of RA, there is a liability of paying VAT for the Religious organization.
Profit Tax, Environmental Tax
In certain cases defined by the Tax Code of RA, the religious organizations can be
- profit tax payer, i.e., while selling the real estate which was the property of the religious organization, or while leasing the property and other cases.
- Environmental tax payer, i.e. while exploiting a central heating station working on natural gas, or possessing vehicle which is the private property of the religious organization and etc.
Meanwhile, the assets (member fees inclusive), works and services received gratuitously by the religious organizations, are not considered as income and are not subject of the profit tax.
The religious organizations as tax agents, while making a payment or submitting an income to physical persons, are obliged on behalf of the physical person to calculate, deduct and pay the income tax. Such cases are: salary payment to the hired employee, income payment to a physical person when purchasing or renting a vehicle or real estate, or for providing services.
It should also be noted that the assets, works and services submitted gratuitously to physical persons by the religious organization are not taxed by the income tax.
It is worth to mention that among religious organizations, based on their nature, the performance of voluntary activities and works on voluntary basis by physical persons are widely practiced as a public beneficial, non-chargeable, free-will work. However, in Armenia the relations of practicing volunteering activities and works by the religious organizations is still not regulated, however there is no legislative obstacle for its application.
The religious organizations as tax agents within the framework of cumulative pension or voluntary pension component, are obliged to calculate and pay the social payment in the amount, within timeframe and according to the procedures defined by the law of “Cumulative pension” of RA.
The religious organizations, as tax agents are obliged to pay the stamp fee for each hired employee in the amount, within the timeframe and according to the procedures defined by the RA law on “Compensation of health or life damage of military servicemen incurred during the defense”.
Real Estate Tax And Vehicle Property Tax
The religious organizations are obliged to make the payments of the local taxes to the community budgets in the amount, within the timeframe and according to the procedures defined in the Tax Code of RA.
- real estate tax – for the land that belongs to the organization by the ownership right and (or) for its improvements (underground or aboveground buildings, edifices or structures)
- property tax for vehicles – for the transportation means that belong to the organization by the ownership right (vehicle, water vehicle working with engine, motorcycle, snow machine, all-terrain vehicle (quadracycle).
Holy Armenian Apostolic Church makes an exception and enjoys the privilege of real estate tax.
According to the Article 230, part 1, clause 8 of the Tax Code, Holy Armenian Apostolic Church is exempted from the real estate tax for
- the churches without the status of a monument, structures used for the production and sale of spiritual-cultural, educational, religious and ritual items, the properties that belong by ownership right and the list of which is prescribed the Government of the Republic of Armenia;
- religious, worship structures under the classification provided for by legislation of the Republic of Armenia, by ownership right or the right to permanent gratuitous use,
- the churches without the status of a monument, structures used for the production and sale of spiritual-cultural, educational, religious and ritual items, workshops ensuring the internal servicing, as well as land parcels necessary for their maintenance and use.
The Application Peculiarities Of Cash Register Machines
In Armenia cash register machines are used for monetary calculations made by organizations, individual entrepreneurs and notaries for transactions in cash or through payment cards or other payment tools based on payment technologies.
It should be noted that in this sphere certain privileges are defined for religious organizations, in particular according to the Article 380, part 3, clause 8 of the Tax Code of RA, for the sale of religious items or for the provision of religious services by religious organizations registered in accordance with the law, where the payment is done in cash or with payment cards or with monetary calculations with the use of payment tools based on payment technologies (including prepayments, partial payments), the use of a cash register machine is not mandatory.
The Religious Organizations In Legal Relations Related To Customs
In Armenia the legal relations related to customs are regulated by the international agreement of “Customs Code of Eurasian Economic Union” dated 11.04.2017 as well as the law on “Customs regulation” of the RA dated 17.12.2014.
Religious organizations are generally subject to the general regulations of customs law, but as a privilege, the VAT regulations of the RA Tax Code provide an opportunity for religious organizations to be exempt from VAT. In particular, according to Article 64, Part 2, Clause 10 of the RA Tax Code, religious organizations are exempt from VAT in case they import goods within the framework of humanitarian aid and charity programs (activities).
It should be noted that when the citizens appointed by the Mother See of Holy Etchmiadzin, finish their ministry in the dioceses of the Holy Armenian Apostolic Church in other countries, while importing their personal items are also exempt from VAT defined by the Law of the Republic of Armenia on Customs Regulation.
The Procedure to Use Privileges in the Framework of Humanitarian Aid and Charity Programs (Activities) for Religious Organizations
Religious organizations of the Republic of Armenia may, in the framework of their humanitarian aid or charity programs, import goods, deliver goods, perform works and provide services, and while supplying goods directly related and significant for the implementation of such programs, or performing works and providing services, they may use the privileges on taxes, duties, mandatory payments defined by law.
It should be noted that from the list of privileges on taxes, duties, mandatory payments, currently only the privilege of VAT exemption is defined.
The procedure and requirements of implying that privilege, as well as the procedure on how to apply to the authorized body, is defined by the government of the RA in the decree N 66Ն on “Charity programs” dated 13.01.2003, and by the law about “Charity” of the RA adopted on 08.10.2002.
Thus, to imply the privileges on taxes, duties, and mandatory payments which are defined by the law, a religious organization must get approval for its charitable program and at least 30 days prior to initiating the program must apply to the authorized body of the Government of the Republic of Armenia, to qualify the program as charity and within the framework of that program to use the privileges defined by the law on getting exempt from the taxes, duties and mandatory payments, in case the above-mentioned privileges or qualification do not directly derive from the legislation or the international agreement ratified by the Republic of Armenia.
The program that is presented for getting the qualification of being charitable should contain the description on the following: purpose of the program, the planned events, data on implementors and beneficiaries of the program. The program should also contain an estimate of projected incomes and expenses, should define the stages and timeframes of the program implementation. The program may also contain description of other circumstances, data and facts and other substantiations, that are considered to be important by the implementors of the program.
To determine the scope of related transactions, the application must describe the transactions which should be carried out within the framework of the program, for which the project implementors expect to implement the tax privileges; the significance of each of the transaction for the implementation of the program should be described and a brief description on the related goods, services and works, as well as their volumes and costs should be provided.
The decision of the authorized body refusing to qualify the program as charitable and to register the program, can be appealed in the court.
It should be noted that after the program is qualified as charitable, the religious organization is obliged to submit relevant reports to the authorized body in accordance with the procedures and timeframes defined in the Government Decree N 66 Ն on the “Charity Programs” of the RA dated 13.01.2003.
The Means for the Protection of the Rights
Religious organizations carry out protection of the rights in tax and customs relations by means of the administrative proceedings, superior appeals, as well as by means of judicial procedure in the Administrative Court of the RA.
The RA law on "Fundamentals of Administrative Action and Administrative Proceedings" is the legal act applicable during the protection of the rights. In particular, the Article 69 of the law provides that to protect their rights the individuals have the right to appeal against administrative acts, including the intervening provisions of associated administrative acts, as well as the action or inaction of the administrative body.
Non judicial means for the protection of rights
The procedure of the administrative appeal is defined in the Article 70 of the law, according to which the act can be appealed
- to the administrative body having adopted the act or superior administrative body of the administrative body having adopted the act through administrative procedure or
- through judicial procedure
- the act has been appealed to the administrative body having adopted the act and/or to the superior administrative body of the administrative body having adopted the disputed act, the appeal shall be subject to consideration in the superior administrative body of the administrative body having adopted the appealed act. In this case, the proceedings of the appeal initiated in the administrative body that has adopted the act shall be subject to termination.
- the act has been appealed through administrative and judicial procedure simultaneously, the appeal shall be subject to court review; in such case the proceedings initiated in the administrative body shall be terminated.
Thus, it should be noted that if there is a dispute in tax and customs relations, then first of all the appeal should be presented to the given administrative body, usually it is the head of tax department or the head of customs department or their deputies. In case the submission of the appeal to the given administrative body is not successful, it is necessary to apply to the superior administrative body by submitting a superior appeal. The superior administrative body is the body that actually governs over the given administrative body, in this case both for tax and for customs relations the superior administrative body is the Appeal Commission of the State Revenue Committee. In case of any superior appeal, regardless of the name of the addressee, the appeal is redirected to the Appeal Commission of the State Revenue Committee of RA.
The tax body examines the application-appeals submitted to the Appeal Commission of Tax Authority and makes decisions on them within 30 days. The calculation of the term defined by this part starts from the first working day following the day of submitting the written application-appeal to the relevant body. In certain cases, by the decision of the head of the tax authority, the period may be extended by 15 days, about which the applicant shall be notified. In case no response is provided to the application-appeal within the mentioned period, the decision of the appeal commission of the tax authority on satisfying the application-appeal shall be considered adopted.
In case the organization missed the time limit of the appeal in circumstances beyond its control, the latter is obliged to collect evidence on the grounds that the appeal was missed because of reasons beyond its control. After eliminating the reason (reasons) due to which the time limit for appeal was missed, the participant of the proceedings may bring an appeal within 15 days, indicating the reason (reasons) of missing the time limit for appeal and substantially examine the appeal. After receiving the petition the administrative body is obliged to examine it, and if there are facts substantiating that the appeal time limit was missed out because of acceptable reasons, then it should be restored and the appeal should be examined.
One year after the expiry of the time limit for bringing appeal, the right to appeal, on the ground of missing the time limit for a valid reason, is expired, except for the cases, when the missing of the time limit for appeal is connected with the consequences caused by force major.
While submitting administrative appeal the requirements mentioned in Article 72 should be considered, which in particular should contain.
- the name of the administrative body to which the appeal is submitted;
- the name, surname, address of the physical person bringing the appeal, and in case of a legal person - the name, registered office of the legal person, name, surname and position of the person bringing the appeal on behalf of the legal person;
- the subject matter of the appeal;
- the claim of the person bringing the appeal;
- the list of the documents attached to the appeal,
- the year, month and day of drawing up the appeal;
- the signature of the person bringing the appeal; in case of a legal person - the signature of the person bringing the appeal on behalf of the legal person.
Bringing an administrative appeal suspends the execution of the disputed administrative act made by the tax and customs body. Except for cases, when the administrative act is subject to execution without delay.
The individual legal act adopted by the tax body, as well as the actions or inaction of the tax officer can be appealed to the Appeal Commission of the Tax Authority in accordance with the procedure defined by the law or to the court.
It should be considered, that the appeal by the taxpayer to the Appeals Commission on the actions (or inaction) of the tax authority or tax officer do not suspend the calculation of penalties. However, in case the appeal or claim submitted to the Appeals Commission or the Court is satisfied, the tax authority makes a change in the records made in the taxpayer's personal account card (including changes in the calculated penalties).
To conduct the proceedings, the Appeal Commission of the Tax Authority shall accept the appeal on the basis of a written application submitted by the taxpayer in Armenian language, which shall contain:
- the name of the Appeal Commission of the Tax Authority to which the appeal is submitted;
- The name of the organization, address, Taxpayer Identification Number TIN, for those who pay VAT, also VAT identification number, the name, surname and position of the person, bringing the appeal on behalf of the legal person; as well as telecommunication details;
- Subject matter of the appeal;
- The claim of the person bringing the appeal;
- the list of the documents attached to the appeal;
- the year, month and day of drawing up the appeal;
- the signature of the person bringing the appeal on behalf of the organization.
The personal legal act, that has been accepted and executed by the tax authority, can be appealed within two months from the day of its entry into force, and the actions or inactions of the tax officer can be appealed within one month from the day of performing any action or demonstrating inaction.
In case the Appeal Commission of the Tax Authority accepts the submitted appeal for further examination, the person who brought the application-appeal shall be notified in advance about the place and time of the relevant commission session. The appeal commission meeting session may be attended by the appellant (the person who brought the appeal), the latter’s chief accountant or the person authorized by the appellant. The absence of the appellant or his / her representative, who have been informed about the place and time of the appeal commission session, is not an obstacle to continue the appeal commission session and to resolve the dispute substantially.
For the sessions of the Appeal Commission of the Tax Authority protocols are drawn, which are signed by all the members present at the Commission session. The protocol signed by the members of the Commission shall be kept in the Tax Authority for three years following the year of its drawing in accordance with the procedure established by the Tax Authority.
The Appeal Commission may make the following decisions on the appeal
- to suspend proceedings of the appeal examination
- to satisfy the appeal
- to partially satisfy the appeal
- to reject the appeal
- to re-examine the appeal
The decision made by the Appeal Commission gets into force the following day it is made.
Judicial Means for the Protection of the Rights
In case of receiving a complete or partial administrative rejection act as a result of a superior appeal, the religious organization has the right to apply to the Administrative Court, which is implemented by filing a lawsuit. Moreover, the religious organization is not obliged to consume the extra-judicial means for the protection of rights; it is eligible to apply directly to the court in case of violation of its rights by the tax and customs authorities.
There are four main types of claims in the Administrative lawsuit: litigation claim, obligating claim, action implementation claim and recognition claim.
The subjects of the claims differ, mainly
- By litigation claim the plaintiff may require eliminating the administrative act partially or completely (including the intervening provisions of associated administrative acts)
- By obligating claim the plaintiff may require adopting the beneficial administrative act, the adoption of which has been rejected by the Administrative body.
- By action implementation act the plaintiff may require implementing certain action or refraining from such actions, which do not support the adoption of the administrative act,
- By recognition act the plaintiff may require recognizing the existence or absence of any legal relations, if he/she cannot file a lawsuit in accordance with procedure as prescribed by the code. By recognition act the plaintiff may also require that the administrative act, be declared null and void, and may also require recognizing the associated administrative act, which no more has any legal force, or the action which is depleted by implementation or by any other way, or the inaction as unlawful, if the plaintiff rightfully is interested in recognizing the act or the action or the inaction as unlawful, that is:
- In similar situation there is a danger of again adopting similar intervening administrative act or danger of again implementing the action
- the plaintiff intends to claim compensation for property damage, or
- It seeks to restore the plaintiff's honor, dignity, or business reputation.
The administrative procedure in accordance with the procedure established by Article 70 allows for more than one claim to be combined in one, if they are directed against the same defendant and are interconnected.
In accordance with the procedure prescribed by the Article 70 the Administrative trial allows to combine more than one claim in one lawsuit, in case they are addressed to the same defendant or are interrelated. Alongside with the litigation, obligatory, action implementation or recognition claims, the plaintiff can make a claim to eliminate those consequences, which have arisen as a result of refusing to adopt the disputable administrative act, or disputable action (inaction) or the administrative act, or as a result of not adopting the administrative act.
It should be noted that the time for filing a lawsuit is limited and the plaintiffs are eligible to file a lawsuit
- in case of litigation claim - within two months right after the day the administrative act enters into force.
- in case of obligatory claim - within two months right after being notified on the rejection of the adoption of the administrative act
- in case of action implementation claim
- within one month right after being notified, that the action implementation is rejected by the Administrative Body.
- within two months after the time limit defined for the implementation of the claimed action is over
- within three months starting from the moment the application for the implementation of the claimed action is presented, if the cases mentioned in points “a” and “b” are not available.
- in case of recognition claim
- regardless of the time, in case it is claimed to recognize the administrative act as null and void
- within 5 years period after the administrative act is considered as lapsed, or from the moment of the expiration of the action or inaction in those cases specified by the 3rd part of Article 69 of the Code.
- within 5 years period from the moment of origin or termination of legal relations in those cases specified by the 1st part of Article 69 of the Code.
It is also worth to mention that the religious organization, as a plaintiff, is obliged to observe the following rules referring the form and the content of the lawsuit. Mainly it is obliged to mention in the lawsuit
- that the lawsuit is filed to the Administrative Court.
- The name of the religious organization, the actual address, the address for the notifications, the TIN, the number of state registration or the number of state registration certificate, the name of its representative, address, if the lawsuit is filed by an eligible officer – the position name of that officer.
- The name of the defendant, the address. In those cases when the defendant is a physical person or a legal body in accordance with the procedure defined by the Administrative trial code of the RA, then the latter’s name (name of the legal body), residential (actual address).
- short description of the essence of the lawsuit
- the facts upon which the claim of the plaintiff is based.
- facts that substantiate the plaintiff’s claim
- the claim of the plaintiff
- information in case the administrative act, the actions or inactions of the Administrative body have been appealed to the superior Administrative Body.
- List of written proofs, if they are attached to the lawsuit
- The year, month and day the lawsuit is filed.
The religious organization can file a lawsuit as a petition to restore the missed out judicial term, indicating the reasons of the omission, if the lawsuit was filed after the expiration of the trial period.
The lawsuit can also contain other information that are essential for the examination and solution of the case, which can include also petitions of the organization.
The lawsuit application is signed by the director of the Religious Organization or by its representative.
The following should be attached to the filed lawsuit
- the original document certifying the payment of the state duty in the amount and procedure prescribed by law, or the relevant pin-code certifying the transfer of the state duty to the relevant treasury account, provided by payment and settlement institution. But if the law gives an option to pay the state duty partially or to postpone or to defer it, then the respective petition should be attached to the lawsuit.
- power of attorney or any other document that certifies the authorities of the representative (in case the trial participants act through a representative)
- petition to invite a witness or an expert, or to appoint an expertise.
- all the written proofs under its control, in case it is possible to attach them to the lawsuit.
- The disputed act or its photocopy, in case it is possible to submit
- the evidence of sending the lawsuit and the copies of all other documents (in case it is possible to photocopy them) to the defendant or to the third parties.
Meanwhile in case the documents attached to the lawsuit are extensive, or it is hard to photocopy them, the plaintiff together with the lawsuit must send a notice to the defendant and to the third parties, where it is says that to get acquainted with them the mentioned documents will be deposited at the Administrative Court.
In Administrative trial the Courts are obliged to examine cases ex officio.
After registering the lawsuit in the proceedings, the Court undertakes the implementation of trial actions, mainly the Court investigates ex officio the factual circumstances of the case, the court is not constrained by the evidences, petitions, proposals, explanation and objections presented by the participants in the administrative proceedings; and on its initiative undertakes adequate means to obtain possible and accessible information on the real facts which are required to resolve the particular case.
At the stage of trial preparation the Court also points out the formal errors existing in the lawsuits, and proposes to specify unclear lawsuit claims, to replace incorrect lawsuit types with proper ones, to differentiate the main and auxiliary claims, to replenish the insufficient factual data, as well as requires to present all necessary evidences to ascertain and evaluate the factual circumstances of the case.
In case the Administrative Court adopts a negative judicial act, the plaintiff has the right to apply to the Administrative Court of Appeal within one month after the publication of the judicial act.
The form and content of the re-examination appeal to the Administrative Court of Appeal is prescribed by Article 134 of the Administrative Trial Code, according to the 1st part of which the re-examination appeal should be drawn in written form, where the following should be mentioned:
- The name of the Appeal Court to which the complaint is addressed.
- The name of the person bringing the appeal and the name of the trial participants (the name of the organization)
- the name of the administrative court, against the judicial act of which the complaint is filed, the case number; the year, month and day the judicial act was adopted.
- The violation of the norm of material or procedural right, which could affect the outcome of the case;
- The substantiations of the violation of the norms of material or procedural right as well as their impact on the outcome of the case mentioned in the re-examination appeal, referring to the decisions of the European Court of Human Rights, the Constitutional Court, the Court of Cassation, which the appellant considers relevant, quoting the sections contradicting to them and performing comparative analysis,
- the claim of the appellant
- the list of documents attached to the appeal
- The position of the appellant regarding any issue of the subject of the appeal, if the appellant was deprived of the opportunity to express his / her position at the Administrative Court.
The appellant religious organization must submit the re-examination appeal and the attached documents to the Court of Appeal, as well as it must send one copy of the re-examination appeal and the attached documents to each of the trial participants, and a copy of the appeal to the Administrative Court which adopted the judicial act.
The Administrative Court of Appeal reviews the judicial act within the frames of the claim presented in the re-examination appeal, and takes all necessary measures to substantially examine the appeal. That is, the Court of Appeal is not constrained by grounds of appeal; and it can conduct an examination into any fact which have been prior examined in the Administrative Court.
In case the Administrative Court of Appeal adopts negative judicial act, the religious organization may submit a cassation-appeal to the Court of Cassation within one month from the moment of its publication. The cassation-appeal must state:
- The name of the Cassation Court to which the appeal is addressed
- The name of the religious organization, the trial status
- The name of the court which adopted the judicial act, the case number, the year, month, and day the judicial act was adopted, the name (names) of the trial participants, the subject matter of the dispute.
- The claim of the appellant quoting the laws and other legal acts, as well as stating which norms of material and procedural rights have been violated or misapplied, or which are the grounds and their substantiations of newly discovered or new circumstances for reviewing the case.
- the substantiations of registering the cassation-appeal in the list of proceedings, that the decision of the Cassation Court regarding the issue mentioned in the appeal may be essential for the similar application of the law and normative legal acts, or there is a appearing fundamental violation of human rights and freedoms.
- The list of the documents attached to the appeal.
The Cassation appeal is accepted for the examination, in case the Court of Cassation considers that the decision of the Court of Cassation on the issue raised in the appeal may be essential for the similar application of the law and normative legal acts, or there is an appearing fundamental violation of human rights and freedoms.
Privileges of the State duties
The 1st part of Article 22 of the RA Law on “State duty” of the RA defines the privileges of the state duties to apply to the Court. According to the “i” subparagraph of the 1st part of the quoted article non-commercial companies are exempt from paying the state duties, including for re-examination and cassation appeals against the court resolutions and decisions for the following cases:
- For the appeals to suspend the case or to cancel the court decision of leaving the appeal without examination; to postpone or to defer the implementation of the resolution; to change the method and procedure of the implantation of the resolution; for provision of the appeals or for replacement of one type of provision with another one;
- For the appeals to review the court resolution or decision as a result of new circumstances;
- For the appeals to waive or reduce the fines imposed by court resolutions;
- For applications to reverse the execution of resolutions of courts, to restore the missed deadlines, as well as for the appeals against the actions of the compulsory executors;
- For the complaints against the court decisions rejecting to waive or reduce the fines, and for other complaints against the courts.
- For the complaints against decisions made by relevant authorized bodies regarding administrative offenses, except for those adopted by the traffic police.
- When claiming cultural property back from the illegal possessor.
In the cases not listed above, the religious organization pays the State Duty in the amount prescribed by the law of RA on “State Duty” in the Article 9, Part 1, Clauses 1, 6, and 7 for the appeals, applications, re-examination appeals and cassation appeals against the court acts of the court submitted to the 1st instance courts.