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.