One of the most aggressive actions taken by the Georgia Revenue Service is the unilateral rejection of an importer's declared transaction value (Method 1) in favor of a higher "market price" derived from their internal database. This administrative adjustment, often referred to as a "Correction of Customs Value," results in an immediate and often retroactive increase in import duties and VAT liabilities. At Legal Sandbox Georgia, we do not treat these assessments as final. We specialize in high-stakes litigation against the Revenue Service to overturn these decisions, arguing that the rejection of the actual price paid was procedurally flawed and substantively incorrect under the Customs Code of Georgia and WTO Valuation Agreements.
Our litigation strategy exposes the common procedural errors committed by customs officers. Frequently, authorities jump straight from Method 1 to Method 6 (the "Fall-back Method") without exhausting the intermediate methods (2 through 5) as required by law. We challenge the comparability of the "reference prices" used by the customs authority, demonstrating that the goods in their database differ significantly in quality, origin, or commercial level from your specific import. We demand that the Revenue Service provide the specific evidence justifying their doubt of your invoice, shifting the burden of proof back onto the state to explain why a genuine commercial transaction is being ignored.
We represent your interests through every stage of the dispute resolution hierarchy. We commence with a formal complaint to the Dispute Resolution Council of the Ministry of Finance, a necessary pre-trial step. If the administrative body upholds the unjust assessment, we proceed to the Tbilisi City Court. Our attorneys draft comprehensive lawsuits supported by independent audit reports, transfer pricing documentation, and payment proofs to compel the court to annul the tax assessment order. A victory in these disputes not only results in a refund of overpaid taxes but establishes a binding judicial precedent that protects your future imports from similar arbitrary revaluations.
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