Legal support for tax disputes for businesses

Disputes arising between legal entities and the state are among the most complex types of legal disputes for businesses. Decisions by the tax authorities can affect not only a company’s financial results but also its business reputation, its ability to work with counterparties, secure bank financing and participate in tenders. This is precisely why, in situations involving additional tax assessments, fines, the blocking of tax invoices, or doubts raised by the tax authorities regarding the validity of business transactions, businesses need not just a lawyer, but a specialist solicitor who is well-versed not only in tax law but also familiar with current case law.

Svarog Law Firm provides comprehensive support for tax disputes involving legal entities: from the initial analysis of documents and preparation of a legal position to representing the client’s interests in dealings with the tax authorities and in the administrative court. Our team helps businesses act strategically rather than emotionally: to assess risks, gather evidence, formulate arguments and choose the most effective defence strategy.

Let’s consider a common example. A company receives a tax audit report in which the tax authority asserts that transactions with a counterparty are ‘fictitious’. On this basis, the tax authority disallows a tax credit, reduces the company’s expenses and imposes additional income tax. Furthermore, the company is charged penalties. Following this, the business receives a tax assessment notice.

At first glance, the situation may seem critical: the accounting documents are in place, the goods or services have actually been received, payment has been made, yet the tax authorities still conclude that a violation has occurred. Often, the basis for such conclusions is information regarding the ‘riskiness’ of the counterparty, or the lack of sufficient labour resources or fixed assets. However, such arguments do not in themselves always prove a violation on the part of the taxpayer.

In such a situation, it is important to engage qualified lawyers promptly. The team at Svarog Law Firm analyses audit reports, source documents, contracts, delivery notes, certificates of completion, payment documents, correspondence with the counterparty, transport documents and other evidence of the reality of the business transaction. Following this, a legal position is formulated for an administrative appeal or a court dispute.

Business owners seek legal assistance after receiving a tax authority decision on additional tax liabilities and are unsure whether it is worth appealing against them. The answer depends on the evidence base, the content of the audit reports, errors made by the tax authority, and the prospects for legal defence. In many cases, it is the court that proves to be the most effective means of defence.

Legal representation in a tax dispute involves drafting the statement of claim, gathering and organising evidence, attending court hearings, preparing procedural documents and objections, and drafting explanations and appeals. The lawyer’s main task is to demonstrate to the court that the company’s transactions were genuine, that the documents confirm the commercial purpose, and that the tax authority’s conclusions are based on assumptions or an incomplete investigation of the circumstances.

A mistake at the initial stage can cost a company significant sums, the seizure of assets, or a protracted dispute with the state. We therefore recommend seeking legal assistance immediately upon receiving tax enquiries, an audit report or a tax assessment notice.

Svarog Law Firm offers businesses professional support in tax disputes, a tailored defence strategy and representation in conflicts with state authorities.