TAX INSPECTIONS

Our services related to tax inspections aim at providing clients with professional support during the time of inspection and avoiding mistakes on the part of client that may happen during the inspection.

We support our clients by actively participating in every stage of tax inspection. To this end we initiate meetings with inspectors in order to provide explanations that may facilitate positive outcome of the case.

The key objective is to eliminate as many as possible controversial issues before the inspection report has been prepared. We strive to achieve this by getting to know as much as possible about potential reservations that inspectors may have and preparing appropriate defence involving review of applicable legal regulations, tax authorities rulings and judicial decisions so that potential post-inspection tax proceeding contains as few as possible issues to be defended in the appeal.

Services in this respect may involve:

• initial meeting with persons responsible for tax settlements to identify and discuss risk areas and prepare reasoning based on official interpretations, judicial decisions and views of legal commentators to be ready at hand when tax inspectors raise those issues
• planning meeting with client’s employees that may have contacts with tax inspectors to explain how to proceed during the inspection, in particular explain the rights and obligations of both parties, guidelines as to providing explanations and documentation to inspectors, fixing deadlines by inspectors and their prolongation
• review of formal aspects of inspection such as authorization to conduct inspection, allowed duration of inspection, our presence and assistance during the inspection or, at the client’s choice, ad hoc emergency advice, prior analysis of documents to be presented to inspectors
• preparation of answers to written questions of inspectors and substantive reasoning regarding reservations raised by them, participation in meetings with inspectors
• reservations and explanations to post-inspection report, representing clients in post-inspection tax proceedings
• preparation of appeals against decisions of tax and fiscal authorities issued in post-inspection tax proceedings
• representing clients before administrative courts

In principle, the above services are at no additional cost to our clients with whom we have regular relationship as they are covered by monthly flat fee arrangement.