Executive Briefing · Tax Controversy
Received an SP2DK? A Structured Approach to the First Response
An SP2DK is a request for explanation, not an assessment. How the first response is prepared can shape what follows.
PrimeTax Editorial Team
04 — Tax Controversy
Respond to tax office enquiries and audits in a structured way, understand your position, and make informed decisions about objection and appeal.
Client situations
A request for explanation of data requires a timely, accurate response. The way it is answered can affect whether an audit follows.
Audits involve document requests, discussions, and deadlines. Preparation and consistent communication help manage the process.
Management must decide whether to accept, object, or pursue other remedies within statutory time limits.
Refund requests typically trigger an examination. Records should be ready before the claim is filed.
Scope of assistance
Engagement process
Review the letter or assessment, deadlines, and the facts behind the issues raised.
Analyse the regulatory basis, available evidence, and the strength of each position.
Recommend a response strategy and prepare submissions for management approval.
Assist through discussions, follow-up requests, and subsequent stages as agreed.
Considerations
Objections and appeals are subject to strict time limits under the General Provisions and Tax Procedures Law (KUP) and the Tax Court Law. Missing a deadline can remove a remedy entirely.
Positions and evidence presented at the SP2DK or audit stage may affect later stages. A consistent strategy from the start is important.
Representation before the tax office and the Tax Court is subject to specific requirements. The scope of PrimeTax's role is confirmed in each engagement.
Summary for general information only. Regulations are applied to the specific facts of each engagement.
How we present exposure to management
Impact
FAQ
Responses are expected within the period stated in the letter. Contact us as soon as it is received so there is time to analyse the data and prepare a considered response.
No. Outcomes depend on facts, evidence, and the decision of the tax authority or court. We provide an assessment of the merits and risks so management can decide how to proceed.
Yes, particularly before filing a refund claim or after significant transactions. Audit readiness reviews help identify gaps while there is still time to address them.
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Structured review, planning, and written opinions that help management understand tax positions before material decisions are made.
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Explore Transfer PricingExecutive Briefing · Tax Controversy
An SP2DK is a request for explanation, not an assessment. How the first response is prepared can shape what follows.
PrimeTax Editorial Team
Article · Tax Controversy
Audit readiness is not about anticipating every question. It is about knowing where your records, reconciliations, and positions stand.
PrimeTax Editorial Team
Share the context of your matter. We will propose a scope and approach for an initial discussion.