The sophistication of tax audits, the increase in tax transparency and greater international cooperation between tax administrations make it necessary for companies to be better prepared in the development of an effective strategy and, in certain situations, to regularize all or part of the previously identified tax risks prior to an audit.

To do this, companies must identify these specific risk areas before the start of an audit in order to prepare clear and detailed explanations by determining and understanding the options available to them.

If, following the tax assessments, adjustments must be made, companies must choose, prepare and exercise the pre-litigation remedies available to them, measuring the impact of any "transactions" envisaged or conceivable.

If points of disagreement still remain at the end of the tax audit, companies must measure the chances of success before any litigation and carefully prepare a technical and detailed argument to maximize their chances of success when they decide to bring a case before the courts.

Our tax experts assist their clients in the management and processing of their disputes and thus provides turnkey solutions to:

  • Anticipate and prepare their tax audits,
  • Effectively manage the conduct of their tax audits,
  • Prepare and pursue appropriate pre-litigation remedies,
  • Effectively challenge upheld tax adjustments before the competent courts.