Comprehensive tax advisory
Tax controversy and disputes
Assisting our clients in tax litigation before administration authorities and administrative courts is an important part of our activities.
Our team members have extensive experience in representing taxpayers in disputes with tax authorities and fiscal audit authorities, as well as courts, including the Supreme Administrative Court.
We have a proven track record of efficacy in tax controversy proceedings with high percentage of cases won. However, we are also eager to tackle cases which are challenging and do not guarantee success. We are fully dedicated to every single case we deal with.
Enodo Advisors team members have represented the clients in tax disputes concerning in particular:
- excise duty imposed on energy producers contrary to the EU law;
- real estate tax;
- discriminatory treatment of investment funds resident in the EU country or the third country in the corporate income tax;
- tax deductible costs recognized on realization of hedging derivatives;
- tax implications in the personal income tax of operations using partnerships;
- VAT and CIT consequences of tooling;
- real estate tax on property which cannot be used in economic activity for "technical reasons";
- numerous cases resulting in refunds of the transaction tax.
How do we assist in disputes with administration?
Our high efficacy in tax controversy proceedings results, among others, from our approach which is based on the fundamental rule: we treat each client's case as specific and plan individual solutions and strategies of litigation.
Whenever possible, we assist our clients at early stages of proceedings (starting from the very beginning of a tax audit or inspection), so as to explain away doubts as they arise and deliver evidence supporting the client's position. We seek to avoid the dispute or settle it successfully at the most early stage possible.
We provide fair estimations of chances to win the case. We co-operate closely with our clients, we consult all steps taken during the proceedings, taking into account the client's expectations.
We act according to the strategy agreed upon in advance which projects possible developments of the case; however, we remain flexible in reacting to shifts and changes in the proceedings as they happen.
To the extent it is possible we build open and fair relation with the tax authorities' representatives, thus creating the positive image of a taxpayer within the tax administration. We know that good working contacts with officials may help find the solution satisfactory for both parties to the dispute. Also, we remember that our Client will deal with the tax authorities on a day-to-day basis even when the dispute is over.