Advance rulings and tax appeals/disputes

ATA Partners offers the preparation of advance ruling request. The service consists of:

  • Preliminary review of the documents related to the advance ruling transactions;
  • Identification and assessment of the tax risks associated with these transactions;
  • Preparation of advance ruling request letter;
  • Participation in discussions together with the Revenue Service regarding the advance ruling request letter.

Advance tax ruling is binding for tax authorities. From taxpayer’s perspective advance ruling is an official approach of tax authorities regarding specific transactions. Taxpayer that acts in accordance with advance ruling is protected by law from any charges and sanctions.

The whole advance ruling process from application to tax authorities to the official reply from them consists of discussions and debates between tax authorities and taxpayer and our involvement in the process is also necessary.

According to the tax code, taxpayer shall not act in accordance with the advance tax ruling if the facts and circumstances referred in an advance tax ruling do not correspond to the real situation or do not provide a complete picture. Thus it is very important that taxpayer describes in details factual circumstances related to the subject of advance ruling when making an application to the tax authority. Otherwise if it is considered that factual circumstances as described in the advance ruling request letter are not real and complete, there may be a risk that the fee paid by taxpayer appear unsuccessfully spent. This is why the role of experienced tax consultant is extremely important in the whole process. Our company offers extensive experience in this regards as well.

ATA Partners will consult you in the course of tax audits and will conduct legal evaluation of the activities of tax authorities.

During the audit process:

  • We will assist you in the process of auditing
  • We will represent you on the appeals within the system of the Ministry of Finance.

After audit process:

  • We will help you to prepare appeal documentation,
  • We will represent you and defend your interests in the Ministry of Finance of Georgia and in the court.