Before the Audit

• Determination of current legal and financial risks
• Risk assessment
• Prevention and mitigation of risk
• Preparation of risk management protocol
• Preparation of audit management protocol
• Preparation of e-notification tracking protocol

During the Review

• Determination of audit type and unit
• Preparation of position paper (Dynamic-Variable PP)
• Coordination-communication management
• Preparation of legal discussions with the auditor
• Explanation of the topics to the auditor
• Preparation of answers
• Support for the preparation of minutes
• Multi-factor process management

After the Audit

• Legal and tax-related analysis for previous periods
• Determination of the roadmap for upcoming periods
• Support for the decision-making process for the determination of the roadmap and legal instruments
• Reviewing the file and expressing opinions
• Attorney services at administrative judicial bodies (tax court/administrative court/Council of State)
• Preparation of case-related strategy documents based on position papers

Acts under Art. 359 of Tax Procedure Law

• Preparation of explanations during the audit
• Determination of explanations during the preparation of minutes
• Explanation and defense of the topic before the Report Evaluation Commission
• Support for the process of giving statements at police stations and prosecution offices
• Execution of criminal proceedings
• Initiation of action for exclusion from special procedures
• Preparation of strategies and explanations third-part client communications

Acts under Art. 362 and 363 of Tax Procedure Law

• Support for the process of giving statements at police stations and prosecution offices
• Execution of criminal proceedings

• Financial law support for penal/commercial disputes/arbitrations
• Peer review support for ongoing disputes
• Support for in-house abuse inspections
• Support for financial agenda of BoD members
• Support for file preparation
• Support for the decision-making process
• Support for corporate communication units
• Support to in-house legal departments
• Support for ruling letter requests
• Support for advanced pricing agreements
• Support to financial departments for the audit process

It covers our peer review services for the regulatory compliance of the following documents to be prepared by the taxpayer or authorized representatives.

• Ruling letter request petitions
• Reply petitions to the Administration
• Presentation file for the Report Evaluation Commission
• File for the Reconciliation Committee
• Files presented to the auditor
• Lawsuit/reply/appeal petitions
• Position papers
• Strategy papers

For important financial issues, we recommend that you receive opinions from an independent and competent party in addition to the current opinion process.

We are experienced in the preparation of written opinions or detailed reports in scientific article standards by taking relevant practices, judicial decisions and literature into consideration.

• Tax Ambassador services (at commissions and meetings)
• Support for the presentation and reporting of sectoral problems
• Support for corporate communication units

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The scope and purposes of our services can be summarized as follows:

• Lawsuit petitions
• Explanation of the sector- or client-specific problem to the authorized body
• Ruling letter requests
• Explanation to the auditor
• Support for the decision-making process of BoD members
• Preparation for negotiations with Reconciliation and Report Evaluation Commissions

• Support for transfer pricing examination processes
• Evaluations for the scope and contents of overseas payments
• Know-how inspections
• Support for Capital Market Board inspection processes
• Analysis for Public Joint Stock Companies

• Individual applications to the Constitutional Court
• Applications to the European Court of Human Rights
• Support for in-house training