One of the main orientations of the activity of the Tax Attorney is the provision of services to protect the interests of taxpayers in arbitration courts under tax disputes which, as a rule, arise based on the results of completed tax audits (both on-site and desk audits), based on the actions of the tax authorities to recover current tax indebtedness (fines, penalties) or based on actions (omissions) by the tax authorities entailing the violation of

the legal rights and interests of taxpayers.

During on-site and desk audits carried out by the tax authorities, the Tax Attorney appraises the current acts and activities of the tax authorities, which includes:

  1. appraisal of requirements to provide documents;
  2. appraisal of documents to be submitted by the taxpayer to the tax authorities;
  3. monitoring, and ensuring compliance with, applicable deadlines as per Tax Code of the Russian Federation;
  4. consultations and recommendations to the taxpayer, etc. 
  5. identify early all instances of procedural incompliance;
  6. minimize tax risks;
  7. help the customer prepare its objections;
  8. form quickly a basis of evidence to defend the legal position of the taxpayer.

The above-specified objects of activity enable to:

If necessary, the Tax Attorney may review and analyze tax disputes that our customers already have, and they can provide opinions on prospects for the resolution of each such dispute based on analysis of tax audit materials, i.e. deeds, resolutions, requirements put forward by the tax authorities, etc.

The list of services provided by the Tax Attorney prior to court proceedings includes the following:

  • legal support during tax control events (Tax Attorney will be on hand whenever on-site audits are conducted by the tax authorities at taxpayers' and will effectuate interaction with the tax authorities whenever desk audits are conducted);
  • conducting analysis of actions (omissions) by the tax authorities with a view to determine whether court appeals can be launched;
  • analysis of deeds reflecting the results of audits and of decisions by the tax authorities with a view to determine whether it is possible to appeal;
  • preparation and implementation of enforcement measures in order to prevent the tax authorities from debiting taxes (fines) from the accounts of taxpayers without acceptance of the latter;
  • drafting and preparation of complaints and appeals against decisions made based on the results of tax audits;
  • representation of the interests of taxpayers before the tax authorities when tax audits are conducted, when tax relief is discussed or when differences arising from the results of tax audits are discussed, etc.

The list of services provided by the Tax Attorney during ongoing court proceedings includes the following:

  • preparation of a legal position with regard to a disputed decision of the tax authorities, taking into account existing court practices and the specific details of the dispute;
  • assistance and recommendations during the preparation of a basis of evidence during court disputes;
  • appraisal of procedural documents prepared by the taxpayer, the possible improvement of such documents, the preparation of recommendations;
  • preparation of applications, motions, appeals and cassation complaints, replies, explanations and other procedural documents and the submission of such documents to courts;
  • participation in the legal processes at all stages of court proceedings.

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