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Litigation with the tax authorities have their own distinct characteristics. The handling of such cases requires special knowledge lawyer not only General procedural and substantive law and rules governing the legal relationship between fiscal authorities and payers of taxes and fees.

Recently in the practice of administrative courts has a new category of cases. Taxpayers petition to the State tax inspection (STI) on the recognition of their wrongful actions, namely in the statement in the inspection report different conclusions (about bestavros and nullity (invalidity) of financial and economic transactions between the plaintiff and its contractors; the recognition of the illegal actions of the STI, which are set out in the inspection report of the findings of overstatement (understatement) tax liabilities (tax credit), etc.

Naturally such active steps taxpayers are not perceived tax inspections adequately. Representatives of the STI is also actively oppose the satisfaction of claims and have in this direction is already well established mechanisms of resistance.

So, in addition to the substantive objections to the merits of the claim, tax authorities often declare motion to close the proceedings with those grounds that inspection acts are not individual legal act, does not violate the rights and interests of the taxpayer, does not give rise to the plaintiff's legal consequences, and therefore the case should not be considered in administrative proceedings. Our staff have developed tactics to counter such attempts and can help You solve existing problems.


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