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Tax Disputes

The UKT Consulting Group will assist you in winning disputes with tax authorities, including those on the results of tax audits. Our services include:

Appeal against the results of on-site and desk tax audits by tax inspections;
Appeal by invalidating of acts, decisions, actions, inactions of tax authorities;
Appeal against the refusal of the tax authority to apply VAT deduction;
Appeal against the refusal of the tax authority to refund VAT;
Appeal against accrual and requirement to pay the amount of tax (including VAT, income tax);
Appeal against imposition of fines and penalties by the tax authorities (tax inspections) as a result of tax audits;
Preparation of notices of opposition to Acts of on-site and desk tax audits.
Preparation of petitions of appeal when appealing against acts, decisions, actions and inactions of the tax authorities out of court;
Appeal against illegal actions of the tax authorities upon the export VAT return;
Appeal against accusations of bad faith, lack of economic feasibility, unjustified tax benefit and the absence of business purpose;
Legal and tax audit of schemes used by the client in business processes;
Judicial review, conduct of litigations (including those appealing against the results of on-site tax audits) with the tax authorities in all courts.

We will draw up and implement a comprehensive plan to protect your rights as a result of tax audit.

The advantages of working with the UKT Consulting Group:

The UKT Consulting Group has got extensive successful experience in the appeal against the results of on-site tax audits, including those for the largest taxpayers.
The successful appeal practice of our company extends not only to Moscow but also to other regions.
In each case, we develop an individual plan of protection particularly for your circumstances, primarily relying on the direct results of the tax audit and specifics of your business.
The ultimate goal of our services is always the achievement of positive results.

The UKT Law Firm has been for many years successfully defending clients in disputes with tax authorities and can confirm its professional level with court decisions now in force on specific cases won.

At present the greatest difficulties in legal disputes with tax authorities arise from the use by courts of the so-called judicial doctrines that are not found neither in civil nor in tax law, however, due to law enforcement practices, the courts go by them in making decisions. So, due to law enforcement practices, there exist the following judicial doctrines:

Doctrine of substance over form
Doctrine of economic feasibility
Doctrine of due diligence
Doctrine of business purpose and others.

Our company will build the Client’s defense taking into consideration the use of current positive judicial practice on particular cases, relying on the decisions of the RF Supreme Arbitration Court (SAC), rulings of the RF Constitutional Court, judicial doctrines, decrees by the Federal Antimonopoly Service of judicial districts and other courts.

So, if you decided to make use of our services in a dispute with your tax office or the supervising tax authority, we suggest that you contact us as early as at the stage of appealing against the respective violation of your rights by a tax authority to the higher tax authority, and then refer to the arbitration court with a claim to annul the relevant act of the tax authority.

If your company is included into a schedule of on-site tax audits, however, you are not sure if the schemes used by you and the arrangement of financial and economic activity of your company are appropriate, we recommend that you contact us for legal and tax audit. The purpose of the audit is to identify risks and hazards in the area of tax law.

After the audit and the accomplishment of our recommendations, you may avoid or reduce, for example, the risk of the on-site audit, reduce the amount of additional taxes, penalties and fines. It must be remembered that corporate raiders and third parties, including your competitors, may use the tax deficiency report against your company as an instrument of pressure, because the violation of tax laws often leads to violations of the criminal law, involving adverse consequences for the company’s management and leadership.