Representation before the NRA

In an inspection, a tax audit or when you receive a letter from the National Revenue Agency, we deal with the NRA on your behalf. We prepare the documents, respond to requests and defend your position within the time limits set by law.

What is included

• Representation in inspections and tax audits.
• Responses to requests for documents and written explanations.
• Review of the audit report and preparation of an objection.
• Preparation of an administrative appeal against the tax assessment notice.
• Ongoing correspondence with the NRA on your behalf.

Representation before the NRA is included in the “Premium” package. For other clients, and for companies that are not our clients, it is agreed separately.

Who it is for

For companies and individuals who have received a request, a summons, an audit report or a tax assessment notice from the NRA. And for those who expect an inspection and want to prepare their documents in advance.

An inspection and a tax audit are different procedures. In an inspection, the NRA usually asks for specific documents or explanations on a particular matter. A tax audit begins with an audit order, covers specific taxes and periods, and ends with an audit report and a tax assessment notice. This determines what needs to be prepared. So our first step is to read the document and establish which procedure has started.

A common cause of problems is not the breach itself but the lack of documents proving that a transaction is genuine: a contract, a handover protocol, proof of payment, correspondence. If such documents exist but are scattered, we help put them in order before the meeting with the revenue authorities.

Statutory deadlines

Time limits in a tax audit are short, and missing them has consequences:

• the audit is carried out within 3 months of service of the audit order; this period may be extended by up to 2 months (source: Art. 114 Tax and Social Security Procedure Code);
• a written objection with evidence may be lodged against the audit report within 14 days of its service; on request, this period is extended by no more than 1 month (source: Art. 117(5) Tax and Social Security Procedure Code);
• the tax assessment notice may be appealed in whole or in part within 14 days of its service (source: Art. 152(1) Tax and Social Security Procedure Code).

If written explanations are requested and not given within the set time limit, the revenue authority may treat the facts as proven or unproven (source: Art. 56 Tax and Social Security Procedure Code). That is why you should contact us as soon as you receive the letter, not in the last few days.

Before the NRA, including in a tax audit, we represent you on the basis of a written power of attorney. The Tax and Social Security Procedure Code does not require notarisation except in specifically listed cases (source: Art. 10(4) Tax and Social Security Procedure Code).

What the client provides

• The letter, request, order, report or notice received from the NRA, with the date of service.
• The documents for the period under review: invoices, contracts, bank statements, accounting reports.
• A power of attorney for representation.
• Your description of the disputed transactions: with whom, why and how they were carried out.

How we work

1. We review the letter or notice received from the NRA and calculate the time limits.
2. We tell you which documents are needed and by when.
3. We collect and organise the documents and prepare the responses, objections or appeal.
4. We represent you and monitor the time limits until the procedure is concluded.

Throughout, you know what has been filed and what comes next. Responses to the NRA are filed in your name and with your documents, so we agree them with you before filing.

If the dispute with the NRA reaches court, we work with partner lawyers.

Frequently asked questions