Practice 05
Tax law and audits
Defence in tax audits, appeals against tax assessments and tax advice — for companies and individuals.
Audits are won in the detail.
We advise on tax matters, defend clients in tax audits and appeal tax assessments before the administrative courts and the Supreme Administrative Court.
The most important work happens early: in the answers to the revenue authority's requests, in the evidence submitted and in the objections to the audit report. What is not said then is hard to prove later.
We work alongside the client's accountants, because a tax dispute is always a dispute about documents.
What we handle
Tax advice
VAT, corporate tax, personal taxes and the tax consequences of transactions.
Audits and inspections
Representation before the revenue authority, answers to requests and evidence.
Objections to audit reports
Reasoned objections and new evidence within the statutory deadline.
Appeals against assessments
Administrative appeal and court proceedings up to the Supreme Administrative Court.
VAT input credit
Defence where input VAT is refused and supplies are alleged to be fictitious.
Security and stays
Defence against the authority's protective measures and stays of enforcement.
Administrative penalties
Appeals against penalty decrees for tax and other infringements.
Transaction structuring
Lawful tax structure for transactions and reorganisations.
How an engagement runs
- 01
Documents
We organise the accounting and primary documents as soon as the audit opens.
- 02
Position
We formulate the position and the answers to the revenue authority.
- 03
Objections
We challenge the audit report's findings with evidence.
- 04
Court
We appeal the assessment administratively and before the court.
Questions and answers
Frequently asked questions
01How long does a tax audit last?
As a rule, up to three months from service of the audit order, extendable by up to three more months. If the audit is suspended — for example for cross-checks or a request to a foreign administration — the total duration can be longer.
02What is the deadline to appeal a tax assessment?
A tax assessment must first be appealed administratively — to the director of the Appeals and Tax and Social Insurance Practice Directorate — within 14 days of service. Without that appeal the court route is closed. The director's decision can then be appealed to the administrative court within 14 days of notification.
03Can I submit new evidence after the audit report?
Yes — with your objections to the audit report, filed within 14 days of its service. This is a key moment: evidence submitted then must be considered in the assessment itself.
04Does an appeal stop enforcement of the assessment?
Not automatically. An appeal generally does not stay enforcement, but enforcement can be stayed if security is provided. Where the amount is significant, this should be planned when the appeal is filed.
Related
Related practice areas
Commercial and corporate law
Company formation, reorganisation and liquidation, Commercial Register proceedings and commercial contracts built around your business.
Learn more
Litigation and arbitration
Court representation before every court in Bulgaria — including both Supreme Courts — and before competition and consumer authorities and arbitral tribunals.
Learn more
White-collar defence
Defence in criminal proceedings for economic offences, offences against creditors and the financial and tax systems, bribery and document offences.
Learn more
Consultation
Tell us about your case.
Describe the matter briefly — we will contact you to arrange a meeting. If a deadline is about to expire, call directly.