Tax and Customs Dispute Resolution

Since each and every step taken in tax and customs investigations and the litigation process will have a direct effect on your business, it is of great importance that the issue be handled by specialists in order to reduce any risks and avoid negative consequences potentially arising.

At GSG Attorneys at Law, we provide consultancy services during all stages of tax disputes, from the beginning of the tax investigation process, to its conclusion. Furthermore, our litigation team also provides consulting services aimed at decreasing risks faced by clients through proactive problem solving seeking to find solutions before a dispute arises.

Tax law and customs legislation is frequently amended and often these amendments directly effect your business. Amendments to the tax and customs authorities’ procedures may impact on day-to-day financial transactions. In such cases, our attorneys will walk clients through the necessary action to be taken, and the related risks clients potentially face.

Consulting Services Provided during Tax and Customs Reviews

Consultancy services from skilled professionals are crucial from the outset of an investigation by tax and customs authorities.  The issues mentioned and the documents submitted to tax and customs inspectors during investigation have the potential to impact negotiations and ultimately the outcome of an investigation.  Statements and documents submitted to the authorities may also be used against those subject to investigation. As expert case managers, our litigation team can oversee developments in an investigation by the tax and customs authorities, and handle the process with utmost care. Moreover, it is extremely important that required explanations and objections are reflected in the signed minutes of pre-trial hearings in terms of the following stages of litigation.

The GSG Attorneys at Law litigation team provides the following services for tax/customs inspection:

  • Attendance with client at pre-trial meetings where minutes are signed, including provision of legal and technical support and counsel
  • Review of ledgers, documents and information requested during a tax inspection prior to submission to a tax/customs inspector
  • Consultation regarding case management and the tax and customs investigation process
  • Research and evaluation of the tax investigation, related legal advice consultation, and preparation of the information and legal arguments to be presented to tax/customs authorities, where required
  • Consultancy and counsel in relation to the addition of required explanations and objection annotations to the minutes after investigation
    • Evaluation of the possibility of reconciliation during the tax inspection
    • Attendance with client at negotiations in front of Report Assessment Committees, including provision of legal and technical support services
    • Calculation of late payment interest regarding tax/customs debts under the scrutiny of litigation.

Consulting Services Provided after Tax/Customs Inspections

Once the tax/customs investigation has completed, the claims covered within the report, tax rulings concerning the subject matter of the investigation, and court decisions are examined.  Subsequently, tax and customs authorities form an evaluation as to whether to resolve the dispute in the administrative stage, or pursue the issue to court.

The GSG Attorneys at Law litigation team provides the following consulting services following a tax investigation:

  • Evaluation of the tax/customs inspection report,
  • Review of the subject matter falling within the scope of litigation from the perspective of legislation and applicable practices,
  • Preparation of a technical evaluation report for the purposes of assisting the decision to apply for reconciliation, or resort to legal action,
  • Evaluation of the possibility of applying for MAP (Mutual Agreement Procedure) where applicable, and advice on the MAP process,
  • Calculation of discounts which can be made at the time of reconciliation,
  • Where the court decision is unfavourable to the client, calculation of late payment interest that will be paid as a result of the lawsuit, and
  • Preparation of statements of claims on objections to additional accruals and penalties made as a result of customs inspections, and follow-up of the objection procedure.

Consulting Services Relating to Tax and Customs Reconciliations

Preparation for the tax and customs reconciliation procedure must be made with the same care as a lawsuit because delivery of a reasoned explanation of the matter at the time of the reconciliation meeting has a material effect on the ultimate outcome of the reconciliation procedure.

The GSG Attorneys at Law litigation team offers the following consulting services during reconciliation:

  • Determination of a competent reconciliation committee and preparation of petitions to apply for reconciliation
  • Review of all dispute related documents
    • Detailed review of inspection reports
  • Review of inspection report calculations in order to avoid material mistakes
    • Review of the subject matter falling within the scope of tax inspection on the basis of tax/customs legislation and in light of court decisions
    • Preparation of a detailed legal opinion to be submitted to the reconciliation committee
    • Assistance in determining the appropriate limits in reconciliation
    • Accompanying the client to reconciliation meetings
    • In the event of reaching reconciliation, checking the compliance of accrual slips with the figures included in the reconciliation minutes
    • Checking the accuracy of interest calculations made as a result of reconciliation

Consulting Services Offered during Trial

In the event of a dispute being taken to court, support from professionals specialising in the topic is out vital importance to the subject of litigation. The issues involved in a dispute include highly technical subjects and for a client to be in the best possible vantage point, these matters must be handled by a legal professional.

The GSG Attorneys at Law litigation team offers the following consultancy services during the trial process:

  • Review of inspection reports and all other documents under scrutiny in the dispute
  • Review of the subject matter falling within the scope of tax investigation on the basis of tax/customs legislation and in light of court decisions
  • Analysis of appendices to petitions and figures which can be sued in the petitions using a basis of company data
  • Follow-up of the entire court process and attendance at all court hearings

Follow-up of procedures to be carried out by the tax and customs authorities in accordance with the outcome of court decisions.

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