Tax Law and Tax Litigation

Tax law governs the balance between the state's power to levy taxes and the rights of the taxpayer. Tax audits, assessment committee decisions and tax/penalty notices produce consequences that directly affect the cash flow and commercial reputation of businesses. Every stage of these proceedings is subject to the strict procedural rules of the Tax Procedure Law No. 213 and the Administrative Procedure Law No. 2577.

Key Areas of Service

• Filing and conducting cases before the tax court against tax and penalty notices
• Protecting taxpayer rights during tax audits; advisory at the report and formal record stage
• Settlement applications and representation at settlement negotiations
• Penalty reduction (Tax Procedure Law Art. 376), invitation-to-explain and voluntary disclosure procedures
• Correction–complaint applications and litigation against rejection decisions
• Litigation against collection measures such as payment orders, attachment and precautionary attachment (Law No. 6183)
• VAT, Special Consumption Tax (SCT), corporate and income tax disputes; allegations of fictitious invoice use
• Import-related assessments at the intersection of customs duties and domestic taxes

Litigation, Settlement or Reduction?

The available avenues interact with one another: a settlement request suspends the litigation deadline; penalty reduction is conditional on not filing a lawsuit; and the likelihood of success in court varies from case to case depending on the basis of the assessment. The right choice can only be made by analysing the legal soundness of the assessment and its financial burden together.

Our Approach

In tax files we conduct a dual-layer review covering both procedure (statute of limitations, notification, audit safeguards) and substance (basis of the tax base, burden of proof), and we tie the process to a strategy aligned with the taxpayer's commercial reality.