Appeal Against NRA Acts

The Challenge

Tax compliance audits have long ago been held on the basis that a company has not been reviewed for a long time.

Today, any tax compliance audit starts with a preliminary analysis which the NRA performs to detect potential tax violations to be audited and to charge the tax and interest due in line with the audit statement or order.

This approach on part of the NRA often predetermines the outcome of an audit in the sense that the conclusions in the statement or order are negative even when the grounds are insufficient.

The Solution

The service is designed to organize successful protection against an anticipated audit act by means of a coordinated strategy which is prepared and implemented to collect evidence and arguments for challenging it as early as the phase of the audit itself.

Scope

• In-depth and detailed investigation of the case, study of the documents and explanations required and submitted in relation to and in the course of the audit;
• Search for possible additional documents and evidence that were not made available during the audit and that could be used subsequently;
• Study and analysis of the entire applicable case law of the Supreme Administrative Court (SAC) and the EU Court of Justice (ECJ);
• Preparation of an overall strategy from the submission of objections to the audit report to the appeal against the statement or order before the final court instance, including an assessment of what evidence and arguments are to be presented at each stage of the appeal and/or a request for a preliminary ruling of the ECJ on the specific case.

Key Benefits

The court proceedings are adversarial procedure between the appellattee team and the NRA lawyers, where the excellent strategy and the perfect choice of arguments and evidence are crucial.

For each case that is related to a tax audit we have a cohesive team of highly experienced lawyers and tax experts who have impeccable knowledge of the proceedings, the subject-matter, and the case law of the SAC and the ECJ.

The high level of expertise and the vast experience in such cases enable us to identify those details, evidence and arguments that can lead to a successful challenge and ultimate repeal of the audit statement or order in each case.