Improved outcomes with one-stop-shop for tax controversies, litigation and arbitration
Ambiguities arise when complex corporate structures operate in an environment that is characterised by a large number of constantly changing tax regulations. These ambiguities, not to mention the different interpretations adopted by national tax authorities, can lead to tax conflicts and double taxation. A company’s ability to manage such situations is an extremely important consideration, particularly at the international level.
We work with you to tackle these challenges, and we ensure that you receive advice related to substantive tax law and procedural law from one source. Using our extensive experience in international tax issues, we will find the right solution for your specific situation. The seamless collaboration between tax advisors and lawyers guarantees the best support available – without inefficiencies and coordination losses.
Together with lawyers, we also offer a wide range of procedural expertise. You enjoy the benefits of our tailored approach when it comes to the prevention of conflicts, settling disputes with tax authorities or in appeal proceedings.
- Support with national and cross-border company audits (joint audits)
- Management of/assistance with national appeal proceedings
- Procurement of binding and non-binding rulings
- Procurement of bilateral and multilateral rulings (e.g. advance pricing arrangements (APA))
- Solutions for cross-border tax conflicts, particularly for transfer pricing, attribution of profits to permanent establishments, relocation of functions (business restructuring)
- Support for bilateral and multilateral mutual agreement procedures (MAPs) and arbitration proceedings
- Process strategy advice (e.g. choice of optimum legal basis for mutual agreement procedures and arbitration proceedings, interactions between national appeal proceedings and international dispute resolution mechanisms)