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Tax Controversy and Dispute Resolution

tax

In view of the growing trend towards sophisticated tax audits, the complexity of the current tax framework and the continuous case law developments, the need to comprehensively and efficiently tackle the constantly arising tax disputes end-to-end is imperative.

We are in a position to address tax controversy challenges and provide customized tax litigation services.

 

Our range of services includes:

  • Legal advice on tax audit procedures and on related enforcement and criminal procedures;

  • Drafting of process documents in the context of tax audit and enforcement procedures;

  • Representation before the tax authorities against tax and penalty assessments after the conduct of audits or in the context of reclaiming the refund of taxes unduly paid;

  • Handling of tax disputes and representing clients before all tax authorities and court instances (e.g. Dispute Resolution Directorate, Greek Administrative Courts including the Supreme Administrative Court, the Court of Justice of the EU and the European Court of Human Rights);

  • Legal advice on alternative dispute resolution (ADR) possibilities (e.g. mutual agreement proceedings under Double Taxation Conventions, arbitration, voluntary disclosure, overdue debt settlement schemes or other tax amnesty schemes as applicable from time to time) and handling of relevant processes;

  • Assistance to criminal defense lawyers in the course of criminal proceedings against managers arising from tax evasion charges.

tax

Our Tax Controversy & Dispute Resolution team has vast experience and know-how in handling complex tax disputes pending before various Greek administrative and court instances on behalf of major multinational companies -including subsidiaries- and individuals in virtually all areas of taxation e.g. corporate taxation, permanent establishment and transfer pricing disputes, indirect taxes (VAT, stamp duties, customs and excise duties), as well as enforcement/restrictive measures and administrative sanctions. We have the expertise in successfully representing clients operating in many sectors spanning various areas of the market and industry spectrum.

 

 

 

Our portfolio or recent projects includes:

  • Complainant MNE operating in the hotel and hospitality industry wins before the Athens Administrative Court of Appeal over a EUR 326 k real estate transfer tax refund application.
  • Complainant MNE operating in the food and beverage industry wins before the Dispute Resolution Directorate over a EUR 975 k VAT refund application dispute.
  • Complainant MNE operating in the insurance industry wins before the Athens Administrative Court of Appeal over a EUR 1,74 M extraordinary contribution plus EUR 1,53 M penalty assessment dispute.
  • Complainant MNE operating in the insurance industry successfully claims repayment of a EUR 1,72 M capital concentration tax amount following a reasoned revocation of its initial tax return and submission of a mandatory administrative recourse.
  • Complainant MNE operating in the automotive industry successfully wins before the Piraeus Administrative Court of Appeal over a CIT assessment dispute involving a total of EUR 363 k of CIT plus penalties and a total of EUR 734 k of tax losses carried forward.
  • Expatriate senior manager of a big group of companies operating in the construction and public works industry wins before the Greek Supreme Administrative Court over a personal tax residence status dispute.
  • Complainant MNE operating in the food and beverage industry wins before the Greek Supreme Administrative Court over a series of customs/VAT assessment disputes, involving a total of EUR 846 k VAT assessment.
  • Appeal in a transfer pricing dispute involving a corporate income tax assessment of €2.2 M and a TP adjustment penalty of €1.1 M;
  • A leading worldwide financial services company before the Administrative Court of Appeal in a tax dispute concerning stamp duty assessment of €11.5 M

Contact us

Georgios Katrinakis

Director

Tel: +30 21 0811 4236

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