Tax consultancy

An individual tax ruling is one of the most effective legal protection tools for taxpayers, allowing them to obtain a binding position from tax authorities regarding planned or actual economic events. Given complex, ambiguous regulations and rapidly evolving judicial practice, relying solely on one's own risk assessment may prove insufficient. An interpretation issued by the Director of the National Tax Information (KIS) protects taxpayers from the negative consequences of changing legal interpretations, ensuring tax security and the personal safety of management. From the moment a questionable area is identified, it is crucial to precisely formulate the factual circumstances and present arguments that will convince the authority of the taxpayer's argument.

Professional preparation of a request for interpretation requires in-depth analysis not only of national regulations and issued interpretations, but also of judgments of administrative courts and the Court of Justice of the European Union. Our support focuses primarily on developing a coherent and logical position and argumentation. The future event described in the request must be fully consistent with the actual operating model or transaction, so that the protection obtained is realistic and unquestionable during a potential audit.

Many applications for tax rulings end with a negative ruling or a refusal to issue an interpretation due to a suspected abuse of the law (GAAR clause). BTTP offers comprehensive support in the event of receiving an unfavorable ruling, and we provide representation in the process of appealing it to the administrative court, seeking to overturn the negative ruling.