Need to involve lawyers at the auditing stage. It is important to defend your interests to the maximum extent at the initial stage, including to file objections to the audit report. The violations established at this stage can be used during the administrative and judicial appeal from the audit findings and will demonstrate the good faith and consistency of the tax payer’s actions.

Application of the administrative appeal procedure concurrently with engagement of the business ombudsman. In case a tax assessment notice is issued, we recommend applying the administrative appeal procedure, especially in case the violations made during the audit are material, and there is a well-established case law in this area. We also advise a complaint against the tax authority’s notice to the Business Ombudsman Council whose inspectors can support the tax payer’s opinion after they study the complaint, which can be an additional argument in the dispute with the tax authority. As we have filed numerous complaints to the Business Ombudsman Council for our Clients’ benefit, we can confirm efficiency of this mechanism.

Thorough preparation for the litigation as well as development of the legal stance based on the applicable case law of the Supreme Court. In case the administrative appeal has been of no use, the next step is judicial appeal from the respective tax assessment notice. The successful outcome requires detailed justification of unlawfulness of the tax assessment notice being appealed, which in its turn depends on the violations detected by the tax authority. That is why the key to success is in-depth knowledge of the land laws as well as peculiarities of the tax laws in connection with the land charges.