Tax Controversy and Dispute Resolution

Dealing with the tax authorities regarding the amount of your tax liability requires not only extensive knowledge of tax and procedural issues, but also practical experience. You should also keep in mind that the Supreme Administrative Court is also able to clarify ambiguous interpretations of tax procedure and, in some cases, change common interpretations of some tax provisions entirely.

For the above reasons, PwC has set up a team of tax procedural specialists prepared to protect your company’s interests at any stage of tax proceedings, from tax audits through appeals to tax remission applications. Our services also include tax litigation.


Our services

Tax proceedings

  • Tax registration and fulfilment of regular administrative obligations
  • Representation of clients during tax audits, including preparation of precise arguments and filings
  • Analysis of decisions made by the tax authorities and recommendations for an appropriate legal remedy
  • Preparation of appeals against decisions made by the tax authorities
  • Use of extraordinary legal remedies – proposals for reinstatement of proceedings, requests for reviews of decisions, requests for remission of tax appurtenances
  • Preparation of legal action to be taken against decisions made by appellate bodies and representation in court proceedings
  • Preparation of cassation claims to be filed with the Supreme Administrative Court or of other constitutional claims
  • Effective use of relevant rulings of national courts and the European Court of Justice in tax and judicial proceedings

Other

  • Preparation for tax audits – verification of the completeness and correctness of documents for tax proceedings
  • Verification of tax periods open to tax audit and estimation of possible tax risks
  • Organisation of training courses and seminars on tax proceedings and dealing with the tax authorities

We have real experience

We have assisted clients

  • successfully defend the tax deductibility of remuneration for managerial services amounting to CZK 100 million;
  • successfully defend value added tax relief with respect to taxable supply totalling CZK 30 million;
  • successfully defend  reduction of the tax base by an estimated payable for an issued credit note in the amount of CZK 70 million;
  • prevent in court proceedings a works contract being reclassified as an agreement on international hire of labour force and subsequent personal income tax assessment in the amount of CZK 1 million;
  • successfully defend in appeal proceedings the tax deductibility of interest costs in the amount of CZK 118 million;
  • demonstrate in appeal proceedings that the approach taken by the tax authority in its tax audit was incorrect, thereby cancelling the additional payment assessments totalling CZK 40 million;
  • preventing in a tax audit managerial services being reclassified as dependent activity, thereby avoiding an additional tax assessment of CZK 10 million;
  • successfully argue during a tax audit the lapse of a prescription period, thereby preventing an additional tax assessment of CZK 3 million;
  • successfully obtain VAT refund of CZK 60 million challenged by the tax office.