Tax audit assistance

Timely consultation with a lawyer on tax audits helps to soberly assess the real prospects of the case, identify weaknesses in the position of the State Tax Service and competently prepare a package of documents to protect the company’s assets. You can contact the specialists of the law firm “Prikhodko&Partners” for this service.

Lawyer services for tax audits

Professional legal protection in the field of taxation is not just the presence of a lawyer during the visit of inspectors, but comprehensive business support at every stage of interaction with the State Tax Service. A competent tax dispute lawyer provides comprehensive support, minimizing any financial and reputational risks for the enterprise.

The following services are offered as part of comprehensive client assistance:

• Legal analysis and initial consultation: detailed analysis of the current situation, study of internal documentation, assessment of the legality of inspectors’ actions and forecasting possible scenarios.
• Assessment of the grounds for conducting an inspection: thorough analysis of STS orders, referrals and notifications for procedural violations, which may be grounds for denying inspectors access.
• Preparation of applications and attorney requests: prompt collection of official information from state bodies and counterparties, formation of a legal basis for client protection.
• Drawing up objections to the tax audit report: substantiated refutation of the conclusions of STS inspectors with references to current legislation and current judicial practice even before the issuance of tax notices-decisions (PPR).
• Formation of complaints and statements of claim: preparation of legally impeccable procedural documents to cancel unlawful STS decisions in administrative or judicial proceedings.
• Representation of the client’s interests: full support of management and the chief accountant during visits to tax authorities, direct participation in the consideration of objections and protection of the interests of the enterprise in courtrooms of all instances.

By engaging a specialized specialist, the business receives a shield that neutralizes administrative pressure and allows the company to operate normally.

When you need a lawyer for tax audits?

Many entrepreneurs make the fatal mistake of thinking that they only need to hire a lawyer when their company’s accounts are frozen. In fact, the help of a tax lawyer is needed much earlier. There are clear indicators and typical situations where delay can lead to catastrophic losses.

You urgently need a tax audit lawyer if:

1. The company received a written request from the State Tax Service to provide explanations and their documentary confirmation. An incorrect answer often becomes an official reason for scheduling an unscheduled inspection.
2. Your company was included in the plan-schedule of scheduled documentary inspections. This is a clear signal to conduct a pre-audit and identify risk areas in advance.
3. Tax inspectors appeared on the doorstep of the office with a referral for an inspection (actual, on-site unscheduled). A lawyer should check the visitors’ authority and the legality of their requirements.
4. The tax service blocked tax invoices or assigned the company the status of a risky taxpayer. This completely paralyzes business activity and spoils relations with partners.
5. Disputes arose regarding transactions with “risky” counterparties. Tax authorities often accuse businesses of carrying out unrealistic (fictitious) business transactions, trying to withdraw tax credits and expenses.
6. You have already been served with a tax audit report with additional tax assessments and penalties. There are strict procedural deadlines for responding that you cannot miss.

Thus, there are a number of situations where quality legal support would be appropriate.

Advantages of cooperation with “Prikhodko&Partners”

When choosing a lawyer in tax disputes, it is important to trust market leaders who have proven cases and deep expertise. The law firm “Prikhodko&Partners” offers clients a systematic approach and uncompromising quality of protection.

Our specialists know in detail the internal algorithms of the State Tax Service, which allows us to act ahead of time. We do not just read papers, but find hidden procedural errors of tax officials that can completely destroy the position of the State Tax Service in court. And when communicating with clients, we do not hide behind complex legal terms. The client always clearly understands at what stage his case is, what risks exist and what strategy we have chosen.

Administrative appeal of tax audit results

After the inspection is completed and the report is drawn up, in case of disagreement with the inspectors’ conclusions, the taxpayer has the right to initiate a pre-trial dispute resolution procedure. Administrative appeal of tax notices of decisions is an important stage that involves appealing to a higher-level tax authority with a complaint about the decision of the local tax inspectorate.

For the procedure to be effective, the complaint must contain concrete evidence, references to the positions of the Supreme Court and primary documents that completely refute the conclusions of the inspectors. If the STS leaves the complaint unsatisfied, the next step is to transfer the dispute to court.

Procedure for appealing the results of a tax audit through the court

When administrative levers are exhausted or impractical, the only effective way to protect a business is to appeal the results of a tax audit in court. This is the most effective and independent way to cancel unlawful fines and additional charges. Judicial procedure requires strict adherence to procedural norms and the construction of an impeccable logic of actions.

A clear algorithm for legal protection consists of several key steps:

• comprehensive analysis of the situation;
• collection and systematization of documents;
• preparation and submission of a statement of claim;
• securing the claim (if necessary, a tax lawyer files a motion to take measures to secure the claim in order to suspend the effect of the PPR for the duration of the trial and prevent any penalties);
• judicial support of the case, which involves direct participation in court sessions, providing oral and written explanations, refuting objections from representatives of the State Tax Service and defending the taxpayer’s position until the court decision is made.

A court decision that has entered into legal force in favor of the taxpayer completely cancels all accrued tax liabilities, returns the company to the status of a bona fide payer, and is the basis for recovering the incurred legal costs from the state.

Stages of cooperation with a lawyer

Interaction with our company is built on a clear, transparent and understandable algorithm. The client always knows what steps will be taken to solve his problem, which eliminates any uncertainty.

The cooperation process consists of the following sequential stages:

• initial client contact and initial consultation;
• defining the goals of the contract and strategy, forming legal terms of cooperation, which clearly stipulate the rights, obligations of the parties and limits of responsibility;
• implementing the strategy, which involves the direct implementation of the agreed work plan, preparation of documents and interaction with state authorities in a turnkey format.

Therefore, case management takes place according to a clear and coordinated plan to ultimately ensure the planned result.

Cost of services of a lawyer for tax audits

One of the most common business issues concerns the financial side of cooperation. We adhere to the principle of individual and honest pricing, so the cost of a tax lawyer’s services is never taken “from the ceiling”. The formation of a budget for legal support depends on such key factors as

• the complexity of the conditions and the amount of the dispute;
• the scope of the lawyer’s work;
• the number of additional tasks (for example, if new circumstances arise during the course of the case);
• the format of the work and urgency.

To find out the terms of cooperation in your case, fill out the feedback form on our website.