Appeal Against NRA Acts

The Issue

Bygone are the times when tax audits were carried out on the basis of the rule that a company had not been audited for a long time.

Today, any tax audit starts with a preliminary analysis which the NRA makes 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.

Objective of the Service

The objective of the service is 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 of the Service

  • 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.

Advantages of the Service

The court proceedings are adversarial procedure between the appellant 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.

Price of the Service

The price of the service is calculated in accordance with the Ordinance on the Minimum Fees of Lawyers, ranging from several thousand to several tens of thousands of BGN, depending on the material value of the claim.


Our team

Metodi Hristov

Managing partner Tax advisory

Metodi Hristov is a graduate of the University of National and World Economy. He started his career as bookkeeper and from 2011 to 2015 he worked as a senior revenue inspector at the Tax Audit department of NRA, where he gained vast experience in taxation. In 2015 he joined the Kreston BulMar team and since 2016 has been a Managing Partner in the accounting practice of the company. He has tens of professional publications and over 20 delivered seminars on taxes and accounting. He has gained vast experience in tax consultancy.

Metodi Hristov was born in Sofia. He exercises at the gym or swims regularly and he often hikes in the mountains. He is interested in literature on personal development and theatre plays.