Tax procedures
Analysis and technical assistance in tax procedures.
A tax procedure is won through method: control of deadlines, a full reading of the file, and submissions that combine evidenced facts, procedural defects and legal reasoning. This is a core area of the practice.
Management, review and audit
- Requests for information and documentation.
- Limited review and data verification procedures.
- Audit proceedings: agreed and contested audit reports.
- Assessment proposals and final assessment decisions.
Penalty proceedings
- Individualised reasoning of culpability and the prohibition of strict liability.
- Reasonable interpretation of the rule and due diligence.
- Proportionality, ne bis in idem and the unity of the infringement.
- Right to be heard, lapse of proceedings and enforcement of penalties.
Administrative and economic-administrative review
- Applications for reconsideration and hierarchical appeals.
- Economic-administrative claims before the regional tribunals (TEAR) and the central tribunal (TEAC).
- Completeness and transmission of the administrative file.
- Enforcement of economic-administrative decisions.
Collection and suspension
- Enforcement orders and enforced collection.
- Suspension of assessments, guarantees and bank guarantees.
- Limitation periods and refunds of undue payments.
- Claims relating to local taxes and charges.
Scope of the work
The work is carried out at administrative and economic-administrative level: analysis of the file, strategy, technical preparation of submissions and organisation of the evidence, where legally appropriate.
Any subsequent court proceedings — judicial review before the administrative courts and further instances — is a different field requiring court representation and advocacy. Those activities are not offered as an own service and must be handled by the corresponding admitted professional.
How the work is done
- A full reading of the notice and the file to identify the real core of the dispute.
- A line of argument that does not rest on a single point: substantive, procedural and evidentiary.
- Strict control of deadlines and of the requirements of each review route.
Work is carried out on the basis of the facts and documentation provided. Where a matter requires activities reserved to qualified professionals — in particular court representation and advocacy — it must be handled by the corresponding admitted professional.
Do you currently have a tax procedure under way? You can set out your case so that it can be assessed.
Submitting the form does not mean the matter has been accepted.