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.
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 successful cases includes:
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;
A Greek Financial Institution before the Administrative Court of Appeal in a tax dispute concerning the refund of credit income tax of €8.1 M due to the deduction of withholding income tax;
The Greek subsidiary of a major multinational automotive company before the Administrative Court of Appeal in several disputes over tax assessments against the company in various tax areas, such as corporate income tax, VAT, withheld taxes on royalty payments, as well as Code of Books and Records penalty and transfer pricing adjustment penalty;
The Greek subsidiary of a leading multinational beverages company before the Administrative Courts of First Instance and Appeal in a series of disputes over VAT assessed by the customs authorities upon the exit of goods subject to excise duties from;
A major Greek franchisee of a multinational franchise in the catering and restaurant sector before the Administrative Court of First Instance in a dispute regarding the imposition of transfer pricing documentation penalties;
A retailer company before the Dispute Resolution Directorate in a dispute over a VAT refund claim amounting to €320.8 K;
An offshore company before the Administrative Court of Appeal in a tax dispute concerning an assessment of income tax of €890 K;
A constructions company before the Administrative Court of First Instance claiming the refund of credit VAT amounting to €129.4 K;