We are pleased to announce that once again we have obtained a favourable settlement for our customers in dispute with tax authorities.
The Provincial Administrative Court acknowledged that tax authorities towards our customers were conducting proceedings in a manner that was contrary to the principle of trust in tax authorities.
Instrumental initiation of criminal tax proceedings for the sole purpose of suspending the limitation period is not approved by administrative courts. Since the Supreme Administrative Court issued Resolution I FPS 1/21 There is no longer a dispute whether the courts can investigate this issue.
The NSA stated that the assessment of the tax authorities’ conditions of application when issuing a tax decision Article 70(6)(1) in conjunction with Article 70c Tax Ordinance within the limits of the judicial review of the legality of that decision.