The tax dispute resolution service covers both pre-trial and court settlements of disputes with tax authorities.

Pre-Trial Settlement

This stage is mandatory under Article 138 of the Russian Tax Code (RTC) and includes:

• Representing the taxpayer before tax authorities, which may involve defending during audits, submitting documents, and substantiating legal positions.
• Preparation of procedural documents, such as objections to audit reports (Article 100 of the RTC) and appeals against tax authority decisions (Article 139 of the RTC). These documents must contain legally sound arguments based on current legislation and judicial practice.
• Participation in audit review meetings, representing the taxpayer in discussions with tax authorities and clarifying disputed issues.
• Challenging unlawful actions or inaction by tax authorities, including document rejection, audit delays, and unjustified penalty assessments.

Pre-trial settlement allows for a faster resolution of disputes and helps avoid the financial costs associated with court proceedings.

Court Settlement

If pre-trial measures do not resolve the dispute, the case may proceed to court. This includes:

• Preparation of legal documents, such as:
  • Statements of claim (Article 125 of the Russian Arbitration Procedure Code),
  • Responses to tax authority claims,
  • Petitions and other procedural documents.
• Representation in courts of all instances, including:
  • The regional arbitration court,
  • Appellate and cassation courts,
  • The Supreme Court of the Russian Federation.
• Evidence presentation, including expert opinions, accounting records, and other supporting documents to substantiate the taxpayer’s position.
• Enforcement of court decisions, ensuring compliance with rulings and securing the refund of overpaid taxes (Article 78 of the RTC).

Objectives and Benefits

The primary goal is to protect taxpayer rights, minimize risks, and reduce financial losses. A professional approach ensures:

✔ Proper document preparation,
✔ Compliance with procedural deadlines,
✔ Qualified representation before tax authorities and courts.

Professional legal support helps achieve fair resolutions and mitigate potential financial losses.