Relationship with the tax administration.
Cultural sensitivity and analysis skills to facilitate dialogue
Activities
Negotiation of preventive agreements (APA) concerning international tax issues.
- Transfer Pricing
- Existence of a permanent establishment
- Attribution of profit to the permanent establishment
- Application of EU directives.
Assistance during tax inspections and in the subsequent litigation phases.
- Support during inspections of the tax administration
- Preparation of appeals before the competent tax courts.
Negotiation of settlement agreements.
Assistance to clients in order to initiate a dialogue with the competent offices to reach a negotiated solution to the dispute.
Mutual Agreement Procedures (MAP).
Activation of procedures (between the tax administrations involved) aimed at settling double taxation situations.
Implementation of Tax Control Frameworks.
Design and implementation of internal systems for the preventive control of tax risks associated with the business operations to be implemented.
Cooperative Compliance Programme.
Assistance in accessing and staying in special programs provided for by current legislation aimed at a constant dialogue with the financial administration.
Professionals
Backed by a strong set of values and beliefs, we foster a highly collaborative culture which helps our clients achieve growth and success.
