Services

Tax Dispute Resolution Services

The specialized team of Deloitte Tohmatsu Tax Co., consisting of former officials of tax authorities and experienced tax professionals, offers advice on the handling of tax audits and assistance in filing administrative appeals and lawsuits.

Major Tax Dispute Resolution Services

The specialized team of Deloitte Tohmatsu Tax Co., consisting of former officials of tax authorities and experienced tax professionals, offers advice on the handling of tax audits and assistance in filing administrative appeals and lawsuits.

• Providing general guidance in dealing with tax audits along with subsequent dispute resolution procedures
• Assistance in preparing and applying for administrative appeals
• Assistance in dealing with reviews from administrative appeal officers
• Assistance in planning arguments and evidence, and preparing litigation briefs
• Making verbal arguments in court as a Licensed Tax Accountant Assessor, in cooperation with legal counsel
• Advising on selecting legal counsel when filing litigation with the court 

Tax Dispute Resolution Services Brochure

For the mitigation of tax dispute risks and the early resolution of conflicts
Unexpected imposition of additional taxes and penalties
The number of cases where significant differences in the opinion of tax examiners and taxpayers over the determination of facts and interpretation of tax law is increasing. Recently, this trend is most often seen in regard to transactions argued to be entered into for a tax avoidance purpose.

A transaction carried out without an intent to avoid tax may be viewed as a tax avoidance scheme during the course of a tax audit, which could subject the taxpayer to unexpected taxes and penalties.
Such risk can be mitigated by appropriately dealing with tax audits, including putting systems into place to always be fully prepared for a possible audit.

Effectively utilize tax dispute resolution procedures and tax accountants!
If the tax auditors issue a tax correction determination, taxpayers who disagree with the determination may request a reinvestigation/reconsideration or file a lawsuit (these procedures are collectively referred to as tax dispute resolution procedures). Although some taxpayers may be reluctant to challenge the authorities, the recent tax dispute procedures are more accessible to taxpayers than ever before, and taxpayers’ arguments are being increasingly accepted. Moreover, the efficient use of tax accountants to expedite the procedures will further promote the speedy settlement of disputed tax issues.
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