Konstantin Pilkov, Cai & Lenard’s Managing Partner
and Head of Tax Law practice, participated in a panel discussion on “Tax Compromise: Latent Risks and Possible Pitfalls. Is it worth trying?”
Participants of the round-table shared experiences on
the application of tax compromise procedure; discussed possible risks for the
taxpayers and their management officials.
Mr.
Pilkov drew the
participants’ attention to the difficulties
that arise in applying tax compromise at the stage of appealing against the tax decision
notices. Also he pointed to the tax authorities’ possible abuses and ways to
obstruct tax compromise. The Code of Administrative Legal Proceedings
provides the possibility to discontinue the proceedings for a period sufficient to reach the tax compromise. But it requires the petitions to be filled by both
parties. There are cases when the tax authorities failed to file the petitions
and court didn’t discontinue the proceedings and issued a decision.” The
difficulties also arise when taxpayer seeks to reach tax compromise on tax decision notices that include into the accrued tax liabilities not only the “released”
tax credit, but VAT liabilities of other nature. The same refers to the profit
tax, because additional taxation may be related
not only to the disallowance of expenses.
To get more information on tax compromise, reed our experts’ article
“Dangerous Tax Compromise” (http://bit.ly/1z09NoF).
Tax compromise: is it worth trying?
Konstantin Pilkov, Cai & Lenard’s Managing Partner and Head of Tax Law practice, participated in a panel discussion on “Tax Compromise: Latent Risks and Possible Pitfalls. Is it worth trying?”
Participants of the round-table shared experiences on the application of tax compromise procedure; discussed possible risks for the taxpayers and their management officials.
Mr. Pilkov drew the participants’ attention to the difficulties that arise in applying tax compromise at the stage of appealing against the tax decision notices. Also he pointed to the tax authorities’ possible abuses and ways to obstruct tax compromise. The Code of Administrative Legal Proceedings provides the possibility to discontinue the proceedings for a period sufficient to reach the tax compromise. But it requires the petitions to be filled by both parties. There are cases when the tax authorities failed to file the petitions and court didn’t discontinue the proceedings and issued a decision.” The difficulties also arise when taxpayer seeks to reach tax compromise on tax decision notices that include into the accrued tax liabilities not only the “released” tax credit, but VAT liabilities of other nature. The same refers to the profit tax, because additional taxation may be related not only to the disallowance of expenses.
To get more information on tax compromise, reed our experts’ article “Dangerous Tax Compromise” (http://bit.ly/1z09NoF).
Practices: