Tax proceedings

 

Tax audit and proceedings
court and administrative

For entities:
  • at which inspection activities, tax control, customs and fiscal control are carried out
  • who intend to raise objections to the inspection report
  • who want to actively participate in all activities during the inspection, intend to submit evidence applications, letters, explanations, want to participate in procedural activities
  • who want to appeal against the decisions of KAS tax authorities
  • who intend to file a complaint with the Provincial Administrative Court, Supreme Administrative Court
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  • to diagnose tax risks in your company, introduce corrective actions
  • for conscious management of the tax risk of planned activities
  • for the preparation of good tax documentation for transfer pricing, if such an obligation arose
  • to use the professional help of a tax advisor
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  • customer case analysis
  • preparation of responses to tax authorities' requests
  • preparation of appeals against decisions of KAS tax authorities
  • preparation of a complaint to the Provincial Administrative Court, Supreme Administrative Court
  • client representation before tax authorities
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Other proceedings

For entities that are party to the proceedings:
  • ORD-IN: on the issue of an individual interpretation of tax law
  • ORD-WS: on issuing an individual ruling as part of a joint application
  • WIS: on issuing the Binding Rate Information
  • APA - Advance Pricing Arrangements
  • MAP - Mutual Agreement Procedure
  • on making a unilateral adjustment
  • on the issuing of the protective opinion
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  • to accurately determine the actual state of affairs
  • to use the professional help of a tax advisor
  • for formal activities related to the course of individual proceedings
  • for conscious management of the tax risk of planned activities
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  • customer case analysis
  • preparation of the ORD-IN, ORD-WS application, application for the issuance of WIS
  • preparation of complaints against the decisions of the authorities issued in the course of individual proceedings
  • preparation of complaints in the course of individual proceedings
  • client representation before tax authorities
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Actions taken
before initiating control -
hedging risks
tax

For entities that:
  • want to secure tax risks
  • they want to know the interpretation of the law made by the tax authorities in their case
  • are interested in analyzing economic events in terms of the possibility of applying the tax evasion clause, and the apparent appearance of economic events
  • they want to know whether their activity constitutes a tax scheme
  • want to know if they are required to report tax schemes
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  • on the economic content of the transactions made and the business case for the transaction
  • at the risk of qualifying the transaction made by the client as artificial by the tax authority
  • due diligence standards
  • for the preparation of scenarios of conduct
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  • preparation of the ORD-IN, ORD-WS application, application for the issuance of WIS
  • conducting a tax audit of the company and preparation of scenarios of conduct
  • preparation of an application for an agreement on transfer pricing
  • preparation of an application for a protective opinion
  • analysis of economic events in terms of the possibility of applying the tax law circumvention clause, the apparent appearance of economic events
  • making a tax characterization of the transaction
  • analysis of obligations and reporting of tax schemes (MDR)
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Fiscal penal proceedings

For entities that:
  • have been held liable in criminal fiscal cases
  • they want to know the consequences of being held accountable in fiscal criminal cases
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  • at risk of being held liable in fiscal criminal cases
  • to fulfill tax obligations, to make timely payments in terms of tax liabilities
  • to verify the reliability of transactions made with contractors
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  • legal assistance during proceedings concerning tax offenses and minor offenses (stage of preparatory proceedings and court proceedings)
  • verification of legal instruments that can be used that may prevent the initiation of penal and fiscal proceedings
  • advice on preventing the initiation of penal and fiscal proceedings
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