Tax Audit and Tax Disputes
The best strategy is prevention. We understand, however, that in your business it is not always possible to anticipate all business decisions. You may not always agree with the tax authority for various reasons, and the tax audit, whether in the form of a local investigation, an action to remove doubt or a tax audit itself, might not be a nice time for the management and the financial department. In order to balance the powers and knowledge of the mutual rights and obligations of both parties during the tax audit, it is a good idea to conduct a possible dispute with full responsibility for its results as early as from its beginnings and make use of all strategic and tactical manoeuvres.
The services we provide:
Representation during local investigation, an action to remove doubt, a tax audit and its whole course up to the discussion on the results of the control findings and signing of the tax audit report;
- Representation during oral negotiations;
- Giving explanation to the tax administrator and removing its doubts;
- Execution and submission of a reply to the tax administrator's invitation to document a fact;
- Proposal and submission of evidence in favour of the client;
- Representation while questioning a witness, during local investigation and other acts of the tax administrator in the course of a tax audit;
- Elaboration and submission of a statement on the results of the control findings;
- Representation while discussing the tax audit report and during the tax audit termination.
If you do not agree with the result of the tax authority's action while auditing the taxes – e.g. after issuance of an additional tax assessment, the dispute can continue as follows:
- By executing and submitting an appeal;
- By representing the client before the Appellate Financial Directorate including proposing and submitting relevant evidence.
Another step of a possible dispute is preparation of a legal action against the decision of the tax administrator. Here, we can help with the following:
- Execution and filing of a legal action specifying all material and legal causes of action that establish the triviality or illegality of the decision;
- Representation before a regional court;
- Proposing and submitting evidence in favour of the client in the course of the judicial proceedings.
The last step of expressing disagreement is filing a cassation complaint to the Supreme Administration Court. In cooperation with a lawyer we provide assistance while:
- Preparing and filing a cassation complaint;
- Representing the client before the Supreme Administration Court.