Legal document templates

Complaint against a notice on tax audit results

Filed with the higher authority (Ministry of Finance / Appeals Commission) to challenge the audit results pre-trial.

Complaint against tax authority officials' actions

Filed when disagreeing with the actions of local tax authority staff.

Application for the mutual agreement procedure

For resolving disputes related to the application of double taxation treaties.

Application for an advance clarification

For participants in horizontal monitoring regarding planned transactions.

Claim challenging an administrative act

Filed seeking full or partial annulment of a burdensome administrative act — for example, annulment of a tax audit notice.

Claim for performance of an action

Filed seeking specific actions — for example, bringing a taxpayer account into compliance.

Compulsion claim

Filed to compel an authority to issue a favourable act — for example, unblocking an account or e-invoices.

Declaratory claim

To establish the existence or absence of a legal relationship, or to declare a lapsed act unlawful.

Damages claim

May be brought together with other claims when damages arise from unlawful tax authority acts or actions.

Motion for interim relief

For temporary measures — for example, suspending a notice until the court issues its decision.

Private complaint

Against court rulings — on return of a claim, imposition of a monetary penalty, or refusal of interim relief.

Appeal / cassation complaint

Against court decisions, whether or not in legal force.

Statement of disagreement

Filed in response to informational or warning notices — from desk audits or VAT registration.

Written objections to the preliminary audit report

Filed when the taxpayer disagrees with the preliminary audit results before the final report is drawn up.

Motion to extend the document submission deadline

When the taxpayer needs more time to prepare the documents requested during an audit.

Document handover act within an audit

Drawn up when handing over documents in response to a tax authority's request during an ongoing audit.

Application for clarification of tax authority actions

Filed when the tax authority's documents are unclear or do not comply with statutory requirements.

Application to confirm notice compliance and lift account / e-invoice blocking

Filed when the taxpayer has complied with the notice but the tax authority does not lift the account restriction or e-invoice block.