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The Constitutional Court held that the right to a fair hearing of a taxpayer subjected to penalised special consumption tax and VAT assessments because a disability report could not be found in a hospital archive had been violated. The same report prod

The fall in the value of fund units, the failure to execute a sale order, the non-payment of the proceeds, the non-return of custodied assets and the incorrect construction of the liquidation account are separate doors; behind each door waits a differe

Accountants can form companies; lawyers are barred. In 2026 the lawyer still earns as an individual and spends as an individual; commercial risk reaches his home and his car. This deserves reconsideration.

The penalty reduction in return for payment added by Law No. 7394 is persistently called “effective remorse” in practice. That is wrong; and it is more than a matter of terminology. The correct name is payment-based penalty reduction.

The Constitutional Court annulled the bar on litigation; can the remaining half of the tax loss penalty still be collected? The principles of legality, ratio legis and interpretation in favour of the taxpayer give the same answer; no.

The taxi driver wants cash, the shopkeeper quotes a different price for card. This dialogue is the sound recording of the country; and the sound appears in the bank’s balance sheet, not in the shopkeeper’s till.

Instalments and restructuring are not the same thing. Deferral under Article 48 of Law No. 6183 carries no reduction, bears 39 percent annual interest and requires a “severe hardship” ratio and security. For the honest SME this is no lifebuoy.

The phrase “may not exceed twice as much again as the 2025 value” in Provisional Article 23, added by Law No. 7566, allows an increase of up to three times the current value and prohibits anything above it.

With the Regulation of 22 November 2025, the transfer of value increases to the public has become a harsh financial obligation at 90 percent. Is a drop from the 100 percent annulled by the Constitutional Court to 90 percent enough to protect the right

Retrospective audits are over, real-time audits have begun. KURGAN’s operational speed is admirable; but the tension between the algorithm and the element of intent raises serious questions of legal certainty.