A tax audit unfolds in successive stages, each with its own deadline — and the choices made at each stage shape the content of the final assessment act. From the notification of the audit order to the final act assessing the tax, the taxpayer is called upon to respond with substantiated arguments, usually within short deadlines.
Our firm takes on a case at whatever stage it stands. We provide advisory support throughout the audit, draft the written positions on the audit findings note addressed to the Tax Administration, file the administrative appeal before the Dispute Resolution Directorate and, if our client is not fully vindicated, bring the case before the Administrative Courts.
In every case we examine both the factual and, above all, the legal grounds that can be raised, and we make full use of every stage of the procedure. Timely legal support ensures that deadlines are met and that every critical argument is raised in good time.
Typical cases
- Businesses and self-employed professionals under a full or partial audit
- Individuals facing a bank-deposit audit or an assessment of unjustified increase in assets
- Taxpayers whose tax was determined through indirect audit techniques
- Cases involving the alleged receipt or issuance of fictitious or forged tax documents, with an administrative and a criminal aspect
- Taxpayers who have received an audit findings note and must respond in time
The process, step by step
Study of the case file
We examine the entire course of the audit, the authority's requests and the material already submitted, in order to identify every factual and legal ground that can be raised.
Written positions on the audit findings note
Following notification of the audit findings note and of the provisional corrective tax assessment (or fine), the taxpayer has twenty days to submit written positions (Article 33 of the Tax Procedure Code).
Review of the final assessment act
We scrutinise the final act assessing the tax and fines, together with the audit report, and identify all of its legal and factual defects.
Administrative appeal and judicial challenge
An administrative appeal is filed before the Dispute Resolution Directorate within thirty days of notification of the act — sixty days for taxpayers resident abroad (Article 72 of the Tax Procedure Code). If the Administration does not fully “revoke” the contested acts, the case proceeds to litigation before the Administrative Courts.