Tax proceedings

Why is this important?

Today, entrepreneurs often seek legal and tax assistance in resolving disputes, as they frequently face challenges in disputes with tax authorities. Managing proceedings step by step—from attempting to settle disputes amicably, providing advice on gathering and preliminarily assessing evidence, representing the client, participating in the entire proceeding, to finally executing judgments against the debtor’s assets or pursuing proceedings against the debtor—is often a lengthy and complex process. That’s why it’s so important to have the support of an advisor specialised in tax and legal proceedings. To avoid disputes and secure oneself, it’s essential to have a proper tax strategy and, in the event of conflict, a well-defined litigation strategy.

How can we help?

Criminal and fiscal criminal liability regulations

  • A document outlining the responsibilities of individual persons within the organisation for the accuracy of tax settlements.
  • Minimises the risk of fiscal criminal liability for those who did not contribute to any potential irregularities in tax settlements.

Internal control instruction

  • Preparation of an internal document regulating procedures and behaviour of employees in the event of the initiation of a tax or customs-tax audit or inspection.

Document verification

  • Developing a litigation strategy.
  • Identifying the documents/evidence needed to best implement the agreed litigation strategy.
  • Analysing the evidence held by the client to assess its potential use as evidence in a tax or customs-tax audit or tax proceeding.

Workshops on the course of a tax or customs-tax audit

  • Preparing the client for the audit.
  • Discussing the course of a tax or customs-tax audit.
  • Indicating the rights of inspectors.
  • Outlining the obligations of the audited party.

Representation during tax or customs-tax audits, tax proceedings, and judicial-administrative proceedings

  • Developing a litigation strategy.
  • Preparing/verifying explanations during the audit.
  • Participating in witness hearings and inspections.
  • Drafting necessary procedural documents, including explanations and objections to the tax audit report, appeals, complaints, and applications to the regional administrative court, and cassation complaints to the Supreme Administrative Court.
  • Representing clients in hearings before administrative courts.
  • Preparing requests for preliminary rulings to the Court of Justice of the European Union.
  • Drafting constitutional complaints and complaints to the European Court of Human Rights.

Representation during enforcement proceedings conducted by the head of the tax office (KAS)

  • Drafting necessary procedural documents, including objections, complaints against enforcement actions, appeals, complaints to the regional administrative court, and cassation complaints to the Supreme Administrative Court.
  • Representing clients in hearings before administrative courts.
  • Participating in enforcement actions.

Feel free to contact us

Warnielo 600x600
Jakub Warnieło

Senior Manager | Tax adviser | Head of Tax Litigation Team
E: jakub.warnielo@mddp.pl