Resolution of tax disputes:

  • Pre-trial settlement of tax disputes (tax audit appeal, administrative appeal of the tax authorities decisions)
  • Judicial Appeal of tax authorities decisions
  • Recovery of losses caused by tax authorities
  • VAT refund, tax refund legal advice
  • Creation of tax planning strategies court precedents
  • Tax audit assistance
  • Legal assistance during interviews and investigative interrogation
  • Subsidiary liability protection and prevention for management and owners

Consultation on tax structuring:

  • Consultation on transaction structuring
  • Tax audit support on contracts, transactional groups, and investment projects
  • Consultation on activities tax structuring
  • Tax Due Diligence
  • Preparation for tax audits
  • Tax audit
  • Identification of tax reserves and overpayments
  • Tax risk analysis
  • Second opinions: a reassessment of tax risks and stress tests
  • Oral and written advice on current tax issues

International tax planning:

  • Advising on international tax matters, including international double taxation agreements, foreign legal entities income tax, cross-border transactions VAT, tax withholding
  • Consulting, analysis, structuring on CFC issues
  • Advice on automatic and bilateral exchange of financial information
  • Advice on tax and currency residency
  • Analysis of currency legislation
  • Advising on “Amnesty of capital”