Tax Law and Tax Protection

Strategic legal support in tax audits, judicial and administrative disputes, and matters with an international dimension

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MStR Law Firm

Taxation is no longer merely a field of formal compliance. For every individual, freelancer, business or company, proper tax management is a critical matter of security, financial planning and protection against risks that may substantially affect assets, liquidity and business activity.

In an environment where tax provisions change frequently, audits are becoming stricter and the interpretation of the rules requires specialised knowledge, timely legal guidance is of particular importance. A tax matter is not determined only at the stage of litigation. It is often determined much earlier, by the way it is organised, documented and supported before the tax administration.

Our firm provides advice, legal opinions and comprehensive legal support on matters of tax law, while also assisting our clients’ tax consultants and accountants. Our support covers, among other matters, issues relating to income tax, VAT, inheritance tax, gift tax and parental grants, real estate taxation, stamp duty, tax fines, surcharges, assessment acts and other disputes with the tax administration.

We place particular emphasis on tax planning in tax matters with an international or cross-border character. The interpretation and application of Double Taxation Treaties is decisive for foreign businesses, foreign nationals living or temporarily residing in Greece, Greek residents abroad, branches of foreign companies, representative offices, joint ventures and other forms of business presence involving a foreign element.

In this context, we examine issues of tax residence, permanent establishment, withholding tax, cross-border tax treatment, avoidance of double taxation and the proper application of international and European rules. The objective is to ensure the client’s safe tax position, avoid unnecessary burdens and prevent disputes with the tax authorities.

Our firm supports its clients in cases involving the imposition of taxes, fines or other sanctions, by drafting and submitting observations, memoranda, objections and intra-administrative appeals before the Directorate for Dispute Resolution of the Independent Authority for Public Revenue (AADE), as well as by taking every necessary action before the competent tax and administrative authorities.

The intra-administrative appeal is a critical stage of a tax dispute, as it precedes judicial recourse and requires full legal substantiation, clear presentation of the facts and proper invocation of the applicable rules. For this reason, we approach each case from the outset with strategic preparation and attention to detail.

In the event of judicial challenge, we undertake the filing of recourses, actions, applications for annulment, applications for suspension of enforcement, objections and other legal remedies before the competent administrative courts. Our objective is the substantive protection of the taxpayer’s rights and the effective response to unlawful, erroneous or disproportionate acts of the tax administration, before the administrative courts and the Council of State.

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At the same time, we cooperate with foreign law firms and international tax and audit firms, accountants and tax advisers on matters of international tax law, tax enforcement in Greece and abroad, challenges to enforceable titles, assessed taxes and fines, as well as cases involving cross-border assistance or a foreign element.

In such cases, particular issues examined include the application of EU law, bilateral and multilateral treaties, the principles of proportionality and good administration, as well as the constitutionally protected rights of taxpayers.

Where required, we secure for our clients independent reports, specialised tax support and continuous written updates, whether they are located in Greece or abroad. In this way, the client has a clear understanding of the matter, the risks, the available options and the proposed strategy.

Our firm’s objective is the substantive protection of individuals, professionals and businesses, the correct interpretation and application of tax legislation and the effective management of every tax matter, both at advisory and preventive level and before the competent authorities and courts.