Tax
Law

Effective business protection in disputes with the State Tax Service (SFS), tax planning and audit support in Moldova.

Focus

When we get involved

Disagreements with fiscal authorities are inevitable as a business grows. We step in when the stakes are high.

Unexpected tax audit

SFS inspectors begin a deep audit of your operations, requesting massive volumes of primary documentation and summoning counterparties for cross-checks.

Additional tax assessments and fines

Following an audit, the tax service issued a decision to reassess VAT, income tax, and impose huge penalties threatening the company.

Account blocking (Asset seizure)

Company operations are paralyzed due to blocked accounts. It is impossible to pay salaries, suppliers, or current taxes.

High fiscal risk transactions

You are planning a complex transaction and want to eliminate the risk of double taxation or future fines.

Our tax law expertise

Deep understanding of law enforcement practice and constant courtroom experience allow us to win complex tax disputes.

Challenging decisions (Tax Litigation)

When the audit act is already on the table and the business needs a challenge strategy.

Administrative and judicial appeal of tax control acts, reassessment decisions, and penalty sanctions.

Business tax support

When transactions and tax requests already require an ongoing tax filter.

Ongoing tax consulting, preparing reasoned responses to SFS requests, evaluating tax consequences of contracts.

Audit representation

When the audit has to be controlled from the inspector's first request.

Support during desk and on-site tax audits. Monitoring the legality of inspector actions, protecting documents.

International taxation

When the group already carries double-taxation and transfer-pricing risk.

Consulting on the application of double tax treaties (DTT), transfer pricing.

Director liability protection

When the tax dispute is already starting to hit the director and accountant personally.

Legal protection of directors and chief accountants from subsidiary and criminal liability for company tax offenses.

M&A tax structuring

When the deal has to be built so tax does not destroy the economics afterward.

Minimizing tax losses during holding restructuring, mergers and acquisitions, and joint venture creation in Moldova.

Our approach to tax disputes

A successful tax dispute is won before filing a lawsuit. Our strategy is based on meticulous preparation of every accounting document.

Express problem audit

We analyze the audit report or SFS decision together with your chief accountant. We evaluate the legality of the inspector's conclusions.

Prospect assessment

We study court practice of the Court of Appeal and Supreme Court of Justice. We honestly forecast the probability of overturning the act.

Preliminary complaint

We form a detailed legal and economic justification of the company's position for appealing to the SFS Dispute Resolution Council.

Evidence base collection

We initiate independent forensic accounting and economic examinations, strengthening our position before the courts.

Court representation

Filing a lawsuit in administrative court with a simultaneous motion to suspend the SFS decision (avoiding forced collection).

Recovery of collected funds

Support in the procedure for returning overpaid or unlawfully collected taxes from the budget to the client's accounts.

Examples from practice

Court decisions speak louder than promises. Typical examples of protecting businesses from fiscal pressure.

Cancellation of multi-million VAT fines

A distribution company was reassessed over 3 million lei in VAT due to subcontractor bad faith.

Result:
We proved the reality of operations and client's due diligence. The SFS decision was fully annulled.
What we did

We dissected the audit act, gathered proof of real operations, and drove the dispute to a full cancellation of the sanctions.

Lifting of unjustified account seizure

The tax service blocked corporate accounts of a logistics company during a lengthy audit, paralyzing international shipments.

Result:
Through emergency judicial review, we obtained recognition of the seizure as disproportionate. Accounts were unblocked within 72 hours.
What we did

We launched an urgent challenge, showed the disproportionality of the measure, and quickly restored access to the accounts.

Transfer pricing dispute

A foreign holding was fined for allegedly artificially lowering prices when selling software to the parent company.

Result:
We engaged independent international auditors for a Transfer Pricing File report and challenged the sanctions pre-trial. The pressure was lifted.
What we did

We brought in independent transfer-pricing expertise and built a strong pre-trial position against the sanctions.

Frequently asked questions

Short answers to what is usually worth clarifying before the first consultation.

When should tax counsel be involved even before an audit or dispute?

Whenever there is already a risk of an audit, a sensitive transaction, reassessments, account freezes, or questions around the tax burden structure. The earlier the position and documents are assembled, the better the chances of keeping the issue out of crisis mode.

Can tax decisions still be challenged if the pressure has already started?

In many cases yes, if the act, documents, calculations, and procedural failures are reviewed quickly and then a pre-trial and litigation line is built. What matters here is not emotion but a precise legal position built around numbers and procedure.

What should be brought to the first consultation on a tax dispute?

Usually the audit report, tax decisions and notices, key primary documents, contracts, and a short explanation of where you see the risk or unfairness are enough. If the file is incomplete, work can still start from the current picture and defense priorities.

Practice

Discuss the strategy and the next step

Leave your contact details and briefly outline the matter. We will return with a clear next step.

All contact details remain confidential.