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;
- 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.