Tax Litigation

Description of the issue

The number of tax disputes as well as their issues, size and intensity continue to increase. There are many reasons for this, including:

  • Challenging (sometimes quite aggressive) interpretations of tax laws;
  • Adoption of the new Tax Code;
  • Inconsistencies in the text of legal and procedural acts;
  • Absence (or limited instances) of correlation between court rulings and actions of tax authorities;
  • Inconsistent rulings by the courts.

How can we help?

Our Tax Litigation team consisting of a unique blend of experienced professionals from legal, tax and accounting backgrounds can provide comprehensive assistance, including:

Before the tax audit:

Reviewing tax, accounting records to identify risk areas;
Providing solutions to mitigate / eliminate risk areas;
Assisting in restoration of tax / accounting records.

During the tax audit and at the pre-litigation stage:

Consulting and legal services during tax audits:

  • Analyzing the legal merits and reasonableness of tax authority demands;
  • Attendance during interviews and other procedures;
  • Drafting responses to tax authority requests;
  • Mediation;
  • Advising and assistance concerning tax authority interviews.

Drafting objections to tax audit statements:

  • Analysing the report’s arguments and the client’s documents regarding the disputed issue(s);
  • Preparing draft objections;
  • Assisting in presenting the objections to the tax authorities.

At the litigation stage:

Drafting an appeal to a superior tax authority:

  • Analysing the tax authority decisions;
  • Preparing the draft appeal;
  • Monitoring the results of the appeal’s review;
  • Liaising with tax authorities.

Representing the client at relevant stages of court proceedings:

  • Drafting procedural documents (claims, counter-objections, etc) to the administrative courts of all instances;
  • Filing documents to the court (including organising the supporting evidence);
  • Representing clients in court proceedings;
  • Monitoring the case during all litigation stages including drafting all procedural documents.