Overview
Tax law covers the creation, assessment, collection and extinguishment of taxes, duties and fees; the rights and duties of taxpayers; tax audits; penalties; and the collection of public receivables. Most tax disputes are heard by the tax courts, though administrative, criminal and other courts may also be involved.
Different deadlines apply to assessment notices, payment orders and attachments, and choosing settlement, penalty reduction or litigation can affect the other options.
What we handle
Tax and penalty notices
Lawsuits against additional assessments and penalties, examining the taxable event, audit reports, calculations, records, limitation and service.
Tax audits
Guidance during audits, review of reports and records, and pre- or post-assessment remedies.
Payment orders and collection
Lawsuits against payment orders (15 days), electronic attachment of bank accounts and seizure of assets.
Precautionary attachment and assessment
Challenging precautionary measures taken to secure public receivables.
Refunds and offsets
Disputes over refused or delayed refunds and offsets, including VAT refunds.
Tax offences
Defence in criminal proceedings concerning false or misleading invoices and books, coordinated with the tax court case.
How the process works
Document and deadline
The notice, payment order or attachment examined; litigation, settlement and reduction periods calculated.
Review of reports and records
Audit report, books and returns reviewed.
Choosing the route
Settlement, penalty reduction, correction or litigation — and their interaction.
Lawsuit
Tax court action, stay of execution where needed; criminal aspects handled in parallel.
Before your meeting
Bring originals or legible copies of whichever of the following you have. You don’t need everything — missing items are identified together.
- Tax / penalty notice, payment order or attachment notice and proof of service
- Tax audit report
- Relevant tax returns
- Books, invoices and bank records
- Correspondence with the tax office
Key deadlines
| Matter | Period | Starts from |
|---|---|---|
| Lawsuit at the tax court | 30 days | Service of the notice |
| Lawsuit against a payment order | 15 days | Service of the payment order |
| Post-assessment settlement request | 30 days | Service of the notice |
These are general rules; special provisions or a different starting date may apply in a particular case. It is best to have the deadline assessed on the day you receive a notification.
Frequently asked questions
I received a tax penalty notice. What should I do?
Note the date of service — the period for litigation and settlement is 30 days. Choosing one route can close others, so review the report and records before deciding.
On what grounds can a payment order be challenged?
Only on the grounds set out in law: that no such debt exists, that it has been paid in whole or in part, or that it is time-barred. The lawsuit must be filed within 15 days.
Does a tax lawsuit stop collection?
A timely lawsuit against an assessment and penalty notice generally suspends collection of the disputed amounts; for payment orders and attachments, a stay may need to be requested.
The information on this page is general and does not constitute legal advice, a guarantee of outcome or an undertaking in respect of any specific matter. Periods and amounts are subject to change by legislation.
