Tax disputes

Business protection during tax audits and disputes with tax authorities. Challenging tax decisions, tax planning, and minimizing reassessment risks.

About the Practice

Tax claims are one of the primary threats to any business. The cost of mistakes or delays can reach tens or hundreds of millions. The firm provides full-cycle legal support — from handling tax audits and preparing responses to administrative and court appeals, as well as criminal defense in tax-related cases.

We act proactively — identifying and mitigating risks before an audit begins and building a defense strategy from the very first contact with the tax authorities.

Tax Audit Support

Legal assistance at all stages of desk and field tax audits.

  • Support during field and desk audits
  • Preparation of responses to tax authority requests
  • Legal analysis of inspectors’ actions and protection against unlawful measures
  • Preparation of objections to tax audit reports
  • Participation in the review of audit materials
  • Interim measures and their challenge

Challenging Tax Authority Decisions

Administrative and judicial appeal of tax authority decisions.

  • Appeals before higher tax authorities
  • Court challenges to liability decisions
  • Disputes over additional tax assessments, penalties, and fines
  • Challenging decisions to suspend bank account operations
  • Refunds and offsets of overpaid taxes

Tax Planning & Compliance

Legal assessment of tax risks and development of sustainable tax models.

  • Tax audits and risk assessments
  • Review of tax optimization structures for compliance
  • Structuring transactions with tax implications in mind
  • Transfer pricing
  • Defense of business purpose and due diligence

Intersection with Criminal Prosecution

Business protection when tax disputes escalate into criminal proceedings.

  • Defense of executives and owners in tax-related criminal cases
  • Coordination of tax and criminal defense strategies
  • Minimization of personal liability in corporate tax reassessments
  • Representation during interrogations and investigative actions

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