- Customs and Tax Audits -

Our lawyers have extensive experience and in-depth knowledge in areas such as tax and customs law, which enables us to effectively represent our clients during customs and tax audits and in tax and customs proceedings initiated based on those audits.

Within the Kopeć Zaborowski Law Firm, a Criminal Tax Practice has been established. It comprises lawyers with many years of experience gained from working in Tax Offices, Customs and Tax Control Offices, and Customs and Tax Services.

Customs and Tax Audit – Our Expertise

Our lawyers have gained experience handling customs and tax audits, including compliance with tax regulations related to income tax for individuals and legal entities, VAT, excise duty, and customs law. Notably, over the years, as officers of the Customs and Tax Services, they have also been involved in combating organized tax crime, such as VAT fraud (including so-called VAT carousel schemes), and conducting financial investigations related to money laundering.

Representation of Clients during Customs and Tax Audits

From the perspective of comprehensive and effective protection of our client’s interests, it is crucial to note that as a law firm, we focus not only on representing our clients during customs and tax audits, tax inspections, tax proceedings, customs proceedings, or verification procedures related to VAT refunds but also represent them in proceedings related to the use of the financial sector for tax fraud, such as STIIR proceedings, involving the blocking of bank accounts suspected of being used for tax crimes, as well as before tax enforcement authorities in fiscal criminal matters, which are often initiated concurrently with tax audits.

Very often, the first actions taken immediately after initiating a customs and tax audit are crucial for the taxpayer’s interests. At this stage, our lawyers assess whether it is appropriate to submit a correction within 14 days of receiving the audit authorization or whether to submit such a correction after receiving the audit result and how this may affect fiscal criminal liability. Our lawyers also assess the effectiveness of suspending the statute of limitations for tax liabilities, especially in light of the increasingly common practice of the tax authorities initiating fiscal criminal proceedings to suspend the statute of limitations for tax liabilities.

To protect our client’s best interests, our lawyers actively participate in all stages of securing, enforcement, and execution proceedings, not only after audits/proceedings have been concluded but especially during their course. This allows for effective protection of our client’s financial interests.

We also represent our clients before administrative courts in the aforementioned areas.

Our lawyers also represent clients in cases related to so-called VAT carousel frauds.

Services Offered by Kopeć Zaborowski Law Firm in Customs and Tax Audits in particular, Kopeć Zaborowski Law Firm provides the following services:

• Representation during customs and tax audits related to compliance with tax regulations, particularly regarding VAT, excise tax, personal and corporate income tax, inheritance and donation tax, and civil law transaction tax.
• Representation during customs and tax audits concerning the compliance with customs regulations and other rules governing the import and export of goods between the EU customs area and third countries, including goods subject to restrictions or prohibitions.
• Representation during customs and tax audits related to compliance with the regulations governing gambling activities under the Gambling Act of November 19, 2009, as amended in 2023, and ensuring that such activities comply with licenses, permits, and approved regulations, including possessing gaming machines.
• Representation during customs and tax audits related to compliance with foreign exchange law, including restrictions and obligations for residents and non-residents, as well as the conditions of foreign exchange licenses and the conduct of currency exchange activities.
• Representation during customs and tax audits related to anti-money laundering and anti-terrorist financing regulations.
• Representation in tax proceedings initiated as a result of customs and tax audits.
• Representation in customs proceedings initiated as a result of customs and tax audits.
• Representation in customs, tax audits, and tax proceedings related to undisclosed income sources.
• Representation in fiscal criminal proceedings initiated concurrently with a customs and tax audit or based on findings from such an audit, particularly about tax offenses and violations of tax obligations, including tax fraud (such as VAT carousel schemes), non-disclosure of taxable items or bases, fraudulent invoices (known as VAT crimes), VAT evasion, improper bookkeeping, customs offenses, smuggling, customs fraud, foreign exchange crimes, and crimes specified under the Penal Code (articles 258, 270, 270a, 271, 271a, 273, 277a, 286, and 299), resulting in the reduction or risk of reduction in public-law liabilities.
• Representation in cases related to extending the deadline for VAT tax refunds by tax authorities.
• Representation in proceedings conducted by the National Revenue Administration to the misuse of bank activities for tax fraud purposes under Article 119zg of the Tax Ordinance Act, such as STIIR proceedings.
• Representation before administrative courts in tax, customs, and enforcement cases.
• Representation before common courts regarding requests for the forfeiture of seized goods under customs law.
• Legal advisory and representation in securing, enforcement, and execution proceedings related to audits and proceedings conducted by the National Revenue Administration.
• Representation before tax authorities in matters involving tax debt relief.
• Participation in all procedural activities related to the aforementioned cases, including hearings, searches, inspections, and forensic experiments.

We encourage you to familiarize yourself with Kopeć Zaborowski Law Firm’s comprehensive offer in fiscal criminal law.

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