Disputes between taxpayers and tax authorities are on the rise. This trend concerns in particular cross-border transactions and originates from an increased focus on matters where there are assessments at stake, such as transfer pricing and business restructuring and general anti-abuse regulations, or where conflicting provisions result in a lack of certainty.

Our team may assist you during tax audits and represent you in negotiations with tax authorities, whenever possible, and at national courts, the CJEU, or in international settlement procedures. Our expertise may be put to use before a controversy in fact arises, by identifying risks, devising defense strategies, preventing disputes, minimizing exposure to penalties, or establishing advance agreements or tax rulings.

The scope of practice encompasses personal income tax, corporate tax, VAT, customs and excise duty, inheritance tax, registration tax and other taxes, in domestic and cross-border matters. Overall, we can support you in the most suitable combination of remedies, including conciliations and mutual agreement and arbitration procedures.

Our tax controversy services include:

• Tax rulings
• Audit support
• Dispute resolution
• Tax court representation
• International conflict resolution proceedings under international and EU law

Where appropriate, we can rely on support from foreign experts of the WTS Global Tax Controversy Service Line in the countries involved.

Please feel free to contact our team and discuss our range of options regarding any uncertain or controversial tax issue.