Tax Litigation

Inspection: We advise and defend clients before the tax inspectorate in procedures to investigate and verify taxpayers’ tax situations.

Collection: We advise and defend clients before the tax collection authorities regarding executive proceedings aimed at collecting tax debts. For example, we defend clients in derivative suits claiming the liability of company managers, suits over company transfers or infringements, and suits filed against shareholders for winding up companies; we oppose administrative methods of enforced collection, seizures and administrative auctions; we advise on all procedures to defer payments and settle debts; and we advise on and negotiate special agreements with the tax authorities and social security regarding temporary receivership and bankruptcy proceedings.

Reviewing administrative action: We advise on and supervise administrative appeals, economic-administrative claims, and judicial reviews before the judicial review courts, the high courts of justice of the autonomous regions, and the Central Criminal and Administrative Court, concerning all types of tax, including direct and indirect taxes, customs, excise duties, parafiscal levies and community export refunds.

Extraordinary appeals: We advise on and supervise extraordinary appeals concerning tax matters, including defending the interests of taxpayers in appeals to the high courts of justice and to the Supreme Court, in appeals for protection and constitutional appeal to the Constitutional Court, preliminary issues before the Court of Justice of the European Union, and appeals to the European Court of Human Rights.

Liability of public administration: We offer legal supervision to clients in liability proceedings against the state for tax decisions that damage taxpayers.

Suspension without provision of guarantees: We advise on and supervise proceedings to suspend the enforcement of tax settlements without the provision of guarantees or with the provision of guarantees other than bank guarantees.

Other administrative proceedings: We advise and defend the interests of individuals and companies before the tax authorities in all kinds of proceedings, such as proceedings to refund unduly paid taxes, to oppose requests for the tax information of third parties, to oppose review procedures initiated by the administration and appeals of administration decisions declaring an act against the public interest, to oppose proceedings involving tax fraud, to oppose tax-related sanction proceedings, and to recover the costs of bank guarantees provided to suspend the enforcement of tax settlements, etc.