The taxpayers may request private tax rulings on tax treatment of specific transactions to get an advance certainty on tax issues of their interest.

If adhered to the private tax rulings, the taxpayers cannot be penalized for tax understatements. Their company officials cannot be charged with criminal liability in such cases.

If a taxpayer disagrees with a tax ruling received or a tax ruling does not provide for a clear answer on the raised questions, such a ruling can be challenged to a court of law. If the court cancels unfavourable tax ruling, the tax authorities must issue a new tax ruling taking into account conclusions of the court. The mechanism of challenging the unfavourable private tax rulings can be an efficient tool to support the favorable tax treatment and mitigate the inherent tax risks.

Our tax rulings assistance services include:

  • Drafting and submission of tax rulings requests

  • Representation in front of tax authorities on the matters raised in tax rulings

  • Challenging the unfavourable tax rulings in the courts of law

  • Representation in front of tax authorities on the matters relating to issuance of new rulings taking into account the conclusions of the court.


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