A large part of businesses survived at least once control of the tax or treasury authority. And in many cases, the use of the term “survived” is the most reasonable. Appropriate preparation for the consequences resulting from the control, including the conscious and full enjoyment of the rights to which the taxpayer is entitled, and adequate explanation, (i.e. when and how it will be sent to the controller), often determines whether the tax proceedings will be initiated.
However, if the tax proceeding has been initiated, the appropriate conduct on the part of the taxpayer almost always increases chances of positive results of the proceeding. The submission of the relevant proposals, including the evidence motions, explanations, identification and justification of Client’s position, building argumentation based on judicial decisions, including the European Court of Justice, and the current practice in other countries of the Community, may result in achieving the three main effects:
- Significant reduction of the finally determined by the tax authorities amounts of the tax overdue and other penalties of a financial nature,
- Preparation of an appropriate strategy, through which it is possible to positively end dispute at the earliest possible stage of the tax proceedings (eventually at the earliest stage of the court proceedings),
- Limitation of the liability, resulting from the penal-fiscal regulations, for those responsible for the management of taxes at the taxpayer.
With adequate knowledge and basing on our experience in disputes with tax authorities, we help our Clients to avoid conflicts, and if it is no longer possible to effectively defend them from tax authorities’ actions.
Our services include:
- Preparation of letters, requests and complaints to the tax authorities for the interpretation of the application of tax law, including oversight of the proceedings in order to ensure the fastest and appropriate response to the Customer;
- Providing assist for Clients and verification of the activities carried out by tax authorities under the fiscal or tax control;
- Preparation of the strategy for the activities undertaken by the Customer prior to the initiation of the tax proceeding, as well as in the course of this proceeding;
- Preparation of drafts of pleadings, including appeals to the higher instance, assisting Client in the process of appeal, as well as Client representation throughout the entire tax proceedings;
- Preparation of the complaints to the voivodship administrative courts and complaints to the Supreme Administrative Court;
- Client representation during the proceedings before the voivodship administrative court and the Supreme Administrative Court.
