The tax compliance climate has changed radically in recent years. The perception of what is avoidance, what is the "right tax" - and what is not - has changed. Tax Authorities often now pursue businesses for tax which would not have been pursued even a few years ago. In some cases, domestic governments have granted tax authorities significant new powers to demand information, collect tax even before it is shown to be due and require corporates to police other taxpayers.
Internationally, the taxation of multinationals has become a matter of public interest and the OECD BEPS project has changed the tax agenda. This change in climate has led to a corresponding increase in controversies and litigation with Tax authorities.
Our team of Tax Disputes specialists across all of the major European jurisdictions have a formidable track record of resolving tax disputes. We advise regularly on tax audits, information requests, settlement of tax claims and subsequent litigation, both at the local level and before international courts including participating in mutual agreement procedures, negotiating on advance pricing agreements and advising on transfer pricing disputes.
Our team members can provide assistance and advice in all of the various stages of any tax dispute. When involved at an early stage, we can advise on investigations, information requests and settlement of claims. Where litigation is necessary we advise regularly on taking tax disputes to the Tax Tribunals and Courts.