Our tax practice is built on a strategic approach that extends beyond traditional tax disputes and places particular emphasis on the tax administration’s increasingly digitalised audit and risk analysis infrastructure. We provide clients with legal counsel and representation in tax audits, tax assessments and penalties, settlement proceedings, invitation to explanation procedures, and tax litigation before the tax courts, combining technical expertise with a strong understanding of industry-specific dynamics.
The analysis of determination letters issued to taxpayers under the KURGAN (Institution-Supervised Analysis System), which has been actively utilised by the Ministry of Treasury and Finance in recent years, constitutes a significant focus of our tax practice. Data comparisons, sectoral benchmarks, and behavioural analyses conducted through the KURGAN system are treated as early indicators of potential tax audits, and the legal implications of such findings are assessed in detail on a case-by-case basis. Our objective is to strengthen the taxpayer’s position and manage risks in a controlled manner before a formal audit process is initiated.
In limited and full-scope tax audits concerning corporate tax exemptions and incentive regimes, tax advantages relating to investment incentives, restructurings, participation income, and financing transactions are evaluated in light of current administrative practice and judicial precedents. In these matters, we seek to anticipate the technical foundations and potential criticisms that may arise in audit reports and develop effective defence strategies before the process reaches the reporting stage.
In sector-based tax audits concerning allegations of improper tax refunds, particular attention is given to the systemic risks associated with VAT refund mechanisms and the methodologies used in chain transaction analyses. Where findings may result in the rejection, postponement, or collateralisation of refund claims, we intervene at the administrative stage and, where necessary, develop robust litigation strategies to protect our clients’ interests.
Allegations concerning the issuance or use of fraudulent or misleading documents, which represent one of the most significant risk areas in tax audits, are assessed not only from a tax law perspective but also in light of potential criminal liability. Counter-investigations, factual findings, and assessments regarding taxpayer intent contained in audit reports are analysed through a multi-layered approach, with the objective of mitigating both severe financial sanctions and criminal exposure.
In invitation to explanation procedures, the scope and methodology of the explanation are determined strategically. A comprehensive risk assessment is conducted prior to submission, and clients are advised regarding potential assessments or audit risks that may arise thereafter. These processes are designed not only to address existing findings but also to strengthen the taxpayer’s overall tax position going forward.
In addition, we closely monitor investigations and tax audits initiated following preliminary findings generated by the Risk Analysis, Evaluation and Research (RADAR) System. Taking into account the system’s analytical methodology and risk thresholds, we assist clients in reassessing their risk profiles and provide strategic guidance throughout every stage of the audit and investigation process.
Our approach to tax law extends beyond representing clients in existing disputes. We aim to help clients achieve a sustainable, predictable, and secure tax position in an evolving tax enforcement environment increasingly shaped by algorithmic risk analysis and data-driven oversight mechanisms employed by the tax administration.
