Favourable outcome of €2,6 million worth dispute against tax administrators


We represented a wholesale distributor of petroleum products against which a tax claim had been filed in 2019. This dispute posed a risk to the company’s financial stability as the claim was made for the amount of €2.6 million.

After applying the substance over form principle, the overpayment was set off against the underpayment where the prescribed period of limitation for the set-off had been expired. It was the first time that the set-off was applied to a legal entity where the decision regarding the application and realization of the set-off was made by two different tax administrators.