Tax disputes

First-hand experience of the tax administration enables us to assess risk realistically, anticipate the authority’s direction of travel and define a defence strategy before adverse findings become entrenched.

Scope of advice

• tax audits and customs and tax inspections
• early assessment of potential allegations and defence strategy
• evidentiary motions, witness examinations and objections to audit findings
• appeals, interlocutory challenges and proceedings before administrative courts
• security measures, administrative enforcement and available remedies
• fiscal criminal proceedings and personal exposure of management
• VAT due-diligence disputes, supply-chain fraud allegations and input tax recovery
• VAT refunds and remedies against excessive delay

One litigation strategy - not a series of disconnected submissions

We bring together the evidentiary record, substantive tax law, enforcement exposure and the criminal or fiscal-criminal dimension. This produces a coherent strategy across proceedings that are often treated separately.