Recently we have noticed a more rigid approach by the tax authorities, both in formal terms regarding requests for informations and terms, but also in material tax affairs such as interest deduction. When negotiations fail, sometimes litigation is required. Where a position bears risks, an opinion can help to map the risks.
Both (the preparation of) a tax litigation and the rendering of an opinion on a specific case are all about arguments and in-depth tax analysis. The (possible) position before a judge is leading. We would be pleased to assist you with our broad expertise in both formal and substantive tax law, as well as extensive litigation experience.
In tax matters, prevention of litigation is an important aspect. However, when it ultimately does come to a judicial ruling, it is key that the case is presented in such a compelling way that victory is the logical consequence. Litigating requires a fundamentally different approach and attitude than advisory and a specific skill-set is essential. Furthermore, being in court with litigating tax inspectors and judges requires substantial experience to emerge from the proceedings with a beneficial outcome.
A tax opinion entails the rendering of an independent statement, which can serve numerous purposes. An opinion can for example prove useful to asses risks in a tax case where there is a lot at stake, but for example also to assess the chances of a certain position in court. Due to our broad expertise, we are able to render opinions on the full scope of Dutch, European and international tax law. Not just (corporate) income tax, but also on topics such as state aid.