Resolution of Tax Disputes
Our primary objective is to identify potential tax risks before they materialize and to take the necessary preventive measures. Through this service, we also aim to ensure that tax audits already conducted at our clients’ premises are managed and concluded in the most effective manner, with our clients’ best interests as the main priority.
During tax practices, differences in opinions and applications that arise between taxpayers and the tax authorities during audits may lead to additional tax assessments and penalties. We support our clients in making accurate evaluations and resolving such matters through settlement or judicial proceedings.
We provide the necessary financial and legal consultancy during the preparation of tax litigation petitions to be filed before Tax Courts.
This includes determining the main legal arguments, preparing annexes to petitions based on company data, conducting numerical analyses to be used in petitions, literature reviews, and research on precedent court decisions.
In Tax Litigation, We Offer
- Fast and effective resolution
- High-quality professional experience
- Strong sense of responsibility
- A dynamic and innovative expert team
- Corporate and structured approach
- Strong legal reasoning and argumentation
Key Considerations and Procedural Matters in Tax Litigation Petitions
- Competent and authorized court
- Exhaustion of administrative remedies
- Legal standing to file a lawsuit
- Whether there exists a final and enforceable administrative act subject to litigation
- Statutory time limits for filing lawsuits before Tax Courts
- Proper identification of the defendant (respondent) in tax cases
- Compliance of petitions with Articles 3 and 5 of the Administrative Procedure Law (Law No. 2577)
- Matters requiring special attention in litigation petitions
- Common mistakes frequently encountered in litigation petitions
- Circumstances leading to the rejection of petitions
- Situations involving changes in the legal personality or status of the parties in tax disputes
- Requests for stay of execution in tax litigation
Common Types of Tax Cases and Special Proceedings
- Lawsuits related to taxpayer status, special circumstances, and key considerations
- Lawsuits related to the tax assessment stage
- Lawsuits filed against irregularity penalties and other administrative fines
- The institution of reservation of rights and lawsuits filed based on such reservations
- Lawsuits filed following applications to the administration, including applications under Articles 10 and 11 of the Administrative Procedure Law
- Lawsuits filed upon learning of tax liabilities or through debt inquiries; lawsuits against payment orders and enforcement (seizure) actions
- Considerations in cases where a file is removed from proceedings
- Lawsuits filed against payment orders, including special circumstances and key considerations
- Lawsuits filed against judicial fees and various administrative charges