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Protecting the taxpayer during tax audits, before the tax tribunals and in the courts. A long-distance race, not a sprint.

Strata
Strata

Layers built up over the years, strata represent what Santana Lorenzo Abogados offers in dealings with the tax authorities: precision layer by layer, tax year by tax year, to give the taxpayer the best protection.

“Audit, appeal and judicial review.”

Protecting the taxpayer begins long before the courts. A tax audit, a verification procedure or a derived liability claim is handled in a procedure with its own rules and strict deadlines, and what is submitted there shapes everything that follows: the appeal before the tax tribunals and, if necessary, judicial review before the administrative courts.

That is why a tax audit is not won at the last hearing but at the first. We balance the scales from the first request for information, taking care over what is submitted and what is said, because the appeal, the judicial review and, if it comes to that, criminal proceedings for tax fraud will all depend on that file. We protect companies, executives and family wealth to the very end: the regional and central tax tribunals (TEAR and TEAC), the High Courts of Justice, the National High Court and the Supreme Court.

Tax audits

Assistance at hearings, submissions, assessment reports and settlements, with a strategy from the first request for information.

Derived liability claims

Defending directors and shareholders against claims for the company’s tax debts (Articles 42 and 43 of the General Tax Act).

Appeals and judicial review

Regional and central tax tribunals (TEAR and TEAC), High Courts of Justice, National High Court and Supreme Court.

Penalties and tax fraud

The line between administrative penalties and criminal proceedings, and the defence in both.

Valuations, residence and related-party transactions

Technical argument supported by our own expert economic evidence.

How we work

We read the whole file before proposing anything. We decide with the client what to contest and what not to, quantify the risk and set the strategy that will serve at every stage, because what goes unsaid during the audit cannot be said later. We work with economists, university professors, auditors and former tax inspectors when the subject matter requires it.

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