Tax Proceedings

For many years, we have been providing legal advisory services to our clients in the broad area of tax and customs law. We place particular emphasis on ensuring that authorities conduct inspections and tax proceedings in accordance with procedural rules and regulations, and that taxpayers can fully exercise their rights during these proceedings.

We advise on current issues regarding the application and interpretation of tax and customs law. We work with businesses from various industries, including pharmaceuticals, FMCG, media, fuel, and real estate development.

The safety and comfort of our clients are our top priorities, which is why we respond promptly in crisis situations, such as preventing or effectively halting enforcement actions, allowing business operations to continue without significant limitations on access to financial resources. On many occasions, as a result of our arguments, tax authorities have discontinued proceedings due to their lack of merit, including on the grounds of the expiration of tax liabilities.

The welfare of every taxpayer is our fundamental value. That is why, in cooperation with the Taxpayer’s Rights Foundation, we assist individual clients and also work to shape favorable judicial lines and legislative changes for taxpayers.

We provide:

• Ongoing legal support for both individual and corporate clients in relation to their daily business activities, with particular focus on tax-related matters;
• Representation of clients before all tax authorities, enforcement authorities, and administrative courts at both levels in all matters concerning the determination or assessment of tax liabilities and customs duties, including anti-dumping duties;
• Representation of clients in administrative matters, including those related to administrative penalties;
• Representation of clients at all stages of preparatory and judicial proceedings based on the provisions of the fiscal penal code, where the cause is contested tax settlements by the authorities.

Our achievements:

• We developed and successfully implemented a litigation strategy during tax and administrative court proceedings, which led to a victory for our client in a case concerning the determination of a CIT tax liability, with the disputed amount reaching several hundred million PLN;
• We have represented clients in hundreds of disputes before tax authorities and administrative courts in matters related to the determination or assessment of tax liabilities (including PIT, CIT, VAT, excise tax, property tax) or the identification of overpayments in these taxes, as well as in customs matters, with a total value of over 1 billion PLN (excluding interest for delays). As a result, many unfavorable decisions or rulings from regional administrative courts have been overturned, or funds paid by clients have been recovered;
• We have represented clients in matters related to the imposition of administrative penalties, leading to the discontinuation of proceedings in these cases;
• We have represented clients in matters concerning the recovery of allegedly unduly paid EU subsidies amounting to several million PLN, resulting in authorities abandoning their attempts to recover these amounts from our clients;
• We have represented clients in matters regarding tariff classification and anti-dumping duties, leading to the discontinuation of proceedings in these cases and the refund of paid customs duties;
• We have represented clients before preparatory authorities and criminal courts, leading to the discontinuation of fiscal criminal proceedings or the acquittal of our clients.