Proceedings before tax authorities and administrative courts
Experienced representation and protection of taxpayer interests
Disputes with tax authorities are one of the most demanding situations for entrepreneurs – they involve the need to make quick decisions, significant financial risk and a significant organizational burden.
We have extensive experience gained in both tax administration and international law firms and consulting firms. We provide professional, comprehensive representation at every stage of the process – from initial audits, through tax proceedings, to appeals to administrative courts.
The scope of our services
We offer comprehensive support from the very first contact with the authority. From the verification stage, which often determines whether an audit will be initiated, we analyze notifications, develop an action plan, and prepare the necessary documents and explanations.
If an audit is initiated, we represent the taxpayer during all activities, such as inspections, interviews, and the preparation of reports. At every stage, we ensure the protection of taxpayers’ rights and ensure that the proceedings are conducted in accordance with regulations and do not violate their rights.
We prepare reliable responses to government subpoenas, evidentiary requests, and objections to audit reports.
Our explanations are based on client interviews, collected documents, applicable tax regulations, and current practice of courts and tax authorities.
If necessary, we arrange expert opinions and support from specialists in other fields, if necessary to defend the taxpayer’s position.
We prepare appeals against administrative decisions and file complaints with the Provincial Administrative Court. We base our procedural position on current case law and administrative court practice to maximize the chances of a favorable outcome.
We provide comprehensive services in preparing complaints to the Provincial Administrative Courts (WSA), cassation appeals to the Supreme Administrative Court (NSA), and other extraordinary remedies in tax matters (applications to reopen proceedings, applications for annulment).
Our support includes:
- analysis of the case files, assessment of the chances of a trial and recommendations for further steps,
- development of legal arguments supported by case law and interpretations,
- preparation of procedural documents in accordance with formal requirements,
- client representation at every stage of court proceedings.
We prepare applications for individual interpretations and applications for security opinions, the purpose of which is to confirm the compliance of implemented solutions with tax law and the practice of tax authorities.
We analyze tax settlements to determine the possibility of recovering overpayments and refunds, prepare appropriate applications, and represent clients in the refund process.
Our approach
Risk-based
strategy
We begin each case with a detailed evidence analysis and risk assessment; we prepare litigation tactics tailored to the specific industry and business goals.
Proactive
actions
We strive to conclude the matter at the earliest possible stage, utilizing procedural mechanisms and maintaining dialogue with the tax authority to limit costs and the impact on the client’s business.
Property
and liability protection
We apply preventive and defensive measures aimed at minimizing financial liability and (if necessary) protecting management board members against the risk of criminal and fiscal liability.
Full
process support
From preparing documents, through representation in inspections, to appearing before the Provincial Administrative Court and the Supreme Administrative Court – we ensure business continuity and a constant flow of information to the client.
How do we operate?
First analysis
and evidentiary security
We quickly review documentation, identify risks, and secure key evidence. We provide recommendations for next steps, along with an assessment of their potential benefits and risks.
Strategy
development
We analyze the situation and select the most favorable course of action: action during the inspection, negotiations with the authorities, appeals, or taking the case to court. We develop a tailored strategy, taking into account the industry and business goals.
Implementation
of process activities
We prepare documents, participate in inspection activities, file appeals, and represent clients in courts.
Monitoring
and communication
We regularly report on progress, provide recommendations, and support in making business decisions.
Contact us to talk about cooperation
Contact
59 Złota Street Skylight Building, 14th Floor 00-120 Warsaw, Poland
