We represent our clients from the initiation of tax audits to the completion of appeal procedures, including representation in tax litigation before administrative courts. It is perhaps less well known that a tax audit is completed when the tax authority draws up a report containing its findings and, more precisely, when it is delivered to the taxpayer. This is followed by the so-called official procedure, whereby the tax administration communicates the findings of the tax audit to the taxpayer in the form of a decision. Once the tax decision has been received, the taxpayer has the right to appeal to the various courts (second instance tax authority, administrative court, Curia).
When a tax audit is launched, the question inevitably arises: who should we ask for professional assistance during the procedure? Obviously, we can count on the cooperation of our accountant or auditor. However, it is also a good idea to get a lawyer who is familiar with tax law involved at an early stage. A question that often arises in tax litigation is whether, once the tax audit has been completed or the final tax decision has been received, the tax deficits, penalties or late payment penalties imposed by the tax authority must be paid. The initiation of court proceedings to review the legality of the tax authority’s decisions does not automatically result in a “postponement” of our payment obligations. Acting on behalf of our clients, we will make every effort, in cooperation with our tax experts and with the help of well-developed accounting/legal professional arguments, to obtain an order from the administrative court to suspend the execution of the final tax decision.
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