Tax practice.

Support for tax audits

There are different types of inspections: desk-based (based on documents without the inspector's presence), scheduled documentary, unscheduled documentary, and actual (with on-site visits). Each has its own grounds, limitations, and payer's rights.

A lawyer for the inspection period is not a presence "for beauty", but a job: monitoring the legality of the appointment, checking the inspector's powers, responding to requests, recording violations, preparing written explanations. Because everything you say or sign during the inspection will later be used in the act - in one direction or another.

Appealing the PPR

The tax notice-decision (TD) is the result of the audit: the amount of additional tax liabilities and penalties. The payer has two levels of protection: an administrative appeal to the higher-level State Tax Service and a judicial appeal to the administrative court.

We prepare objections to the inspection report before issuing a PPR, a complaint in the administrative appeal procedure, a lawsuit to the district administrative court. In most cases, the combination of administrative level + judicial level works, because success at the administrative level allows you to avoid going to court, and loss does not block further judicial appeal.

VAT issues

A separate layer of work. Blocking of tax invoices of the Tax and Customs Administration - we prepare a table of payer data, explanations, if necessary - appeals. Budget VAT refund - support of the application, response to requests, appeals of refusals.

Registration and cancellation of VAT payers, refunds of overpayments from the budget, disputes regarding the reality of business transactions (especially in supply chains) - all this also applies to this practice.

Criminal tax cases

Article 212 of the Criminal Code of Ukraine (tax evasion) is the most common norm in tax criminal law. Next to it are Art. 358 (forgery of documents), Art. 366 (official forgery), legalization clauses. Often, criminal proceedings are opened in parallel with an administrative case, based on the same inspection acts.

We protect the suspect, witness, accused at all stages: pre-trial investigation, investigative actions, searches, interrogations, familiarization with materials, trial. We separately monitor the relationship with the administrative case - the outcome of one often affects the other.

Tax planning

Structuring a business for the optimal tax model - before problems arise. Choosing a taxation system (general, simplified, single group tax), choosing an organizational form, forming supply chains, currency control in foreign economic activity.

Separately - the transition between taxation systems, restructuring of a group of companies, analysis of planned transactions for tax consequences. This is work where a good result is measured not by a won dispute, but by a dispute that never arose.