Services

Tax Appeal and Litigation Service

The more we fight for it, the fairer tax will be

Tax appeal and litigation are a means of making tax fairer. When you are facing a questionable assessment notice, we examine whether that notice is based on accurate facts and correct interpretation of tax laws. Further, we offer total support by handling the tax appeal and tax litigation on your behalf.

What should you do in facing a questionable assessment notice?

A difference of opinion between a taxpayer and the tax authorities in a tax audit over whether, when and how much the taxpayer is obliged to pay often occurs. The main cause of such differences is a misalignment between the facts regarding the taxpayer’s transactions or assets and those assumed by the tax authorities. Although this misalignment could be resolved through frank debate during the tax audit process, it is still not unusual for unresolved differences of opinion to lead to a tax assessment notice.

If you believe you have received an unfair assessment notice, you should first examine whether it is based on accurate facts. It is also necessary to verify there are no misinterpretations of tax laws.

If the examination finds the assessment notice to be in error, you can correct the erroneous assessment notice and receive a refund for overpaid taxes through tax appeal and tax litigation. Given your accountability to stakeholders such as shareholders, banks and business partners, you are required to deal with questionable assessment notices appropriately.

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Our services

When you are facing a questionable assessment notice, we examine whether that notice is based on accurate facts and correct interpretation of tax laws. We also provide consulting services regarding chances of winning, procedures and costs if you decide to proceed with tax appeal and litigation, as well as how to disclose the assessment notice to the public. Further, we offer total support by handling the tax appeal and tax litigation on your behalf.

 

Deloitte Tohmatsu has particular strengths in tax appeals

If a taxpayer files a tax appeal with the National Tax Tribunal, it will listen to the cases of both the taxpayer and the tax authorities, perform its own summary and review of the facts, and issue a decision from a third party’s viewpoint, not open to the public and free of charge. This is a procedure that enables a taxpayer to correct an erroneous assessment notice based on incorrect facts sooner. Even if tax litigation becomes necessary, clarifying contention points in advance allows tax litigation to proceed efficiently.

Our team consists of lawyers, certified public tax accountants, and ex-tribunal officials with extensive expertise, experience, and successes in tax audit defenses and dealing with tax appeals and tax litigation. We work closely with the tax filing and advisory teams, and we are involved in tax appeals on a daily basis. We have amassed powerful know-how on tax appeals in particular.

Tax Controversy Japan Updates

This article provides an overview of areas of focus and the tax audit and controversy procedure in relation to national tax (excluding customs duty) in Japan.

>> Click [Tax Controversy Japan Updates] for more details

Japan Inbound Tax & Legal Newsletter

>> Click [Japan Inbound Tax & Legal Newsletter] for more details

Professionals

Yutaka Kitamura

Yutaka Kitamura

DT Legal Japan, Attorney-at-law

Practice Yutaka Kitamura supports many large companies, foreign companies and wealthy individuals in defensing tax audits and conducting tax appeals and tax litigation. Professional Experience 2000 Na... More

Takashi Tezuka

Takashi Tezuka

DT Legal Japan,Attorney-at-law

Practice Takashi has been advising verious types of entities from small and medeum sized corporations to multinational conglomerates. His areas of practices are tax planning, tax disputes (both nation... More