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Tax Controversy & Dispute Resolution
Tax regulations continue to grow in number and become increasingly complex. At the same time, tax authorities are deepening their scrutiny over taxpayers. Our Tax Controversy & Dispute Resolution team is here to help you navigate this more uncertain tax world before, during and after new challenges arise.
Your tax challenge
Tax authorities are focusing increasingly on implementation failure and motive – not just pure tax technical merit or analysis.
Information requests you receive after filing your Luxembourg tax returns should not be considered simple letters. Your response may have an impact on your future tax assessment, and any potential tax dispute may be fed by information you share. This is also true for requests received from the Luxembourg tax authorities in the context of exchange of information with foreign tax authorities.
As taxpayers, you should also take care to review the Luxembourg tax assessment from the Luxembourg tax authorities. If the tax assessment diverges from your tax return position, you should determine, on a case-by-case basis, whether the position could be questionable on the merits and/or form.
How Deloitte can support you
The tax experts at Deloitte can support you when a tax dispute arises, but we would also like to help you avoid a tax dispute at all. From the way your organization approaches tax to your tax documentation management and interactions with the Luxembourg tax authorities, we can support you beforehand to mitigate risk of tax dispute.
We successfully assist clients in each phase of the tax controversy life cycle:
Dispute prevention
Our assistance covers the full spectrum from the review of your current operating model, tax policy and governance, as well as supporting documentation. When filing your tax returns and taking tax positions, we can assist you in preparing a dedicated file to support your tax positions. With such documentation, you as the taxpayer should be in a position to efficiently and easily answer any request from tax authorities – even if these questions come several months or years after the tax filing.
Tax investigations and tax audits
We can bring our expertise to support you in responding to tax investigations and tax audits initiated by Luxembourg tax authorities and even foreign tax authorities with the support of our network of experts.
We can help you draft supporting argumentation to answer information requests from the Luxembourg tax authorities. We can also bring our experience to helping you check if the requests make sense or if they could be fishing expeditions (the answer to which may be beyond the collaborative obligations expected from a taxpayer).
The breadth of our experience also includes assisting with exchanges with the tax authorities.
Post-audit settlement or dispute resolution
We can assist you in drafting supporting argumentation of pre-litigation claims with tax authorities and will be with you every step of the way as you prepare for court proceedings (with the assistance of external fully qualified lawyers as required).
Equally important, we also support clients in alternative dispute resolution mechanisms through competent authority and mutual agreement proceedings to resolve international tax disputes resulting from issues such as double taxation.
The experience we can bring to you
Our Tax Controversy & Dispute Resolution team assists taxpayers facing this challenging tax environment. The diversified experience of our experts is combined to help our clients prevent, efficiently manage andresolve tax audits and disputes. Integrated in a worldwide network, our specialists not only focus on the Luxembourg aspects, but also integrate cross-border risks and impacts.
Contact our tax experts today to learn more about our Tax Controversy & Dispute resolution services.
Contacts
Julien Lamotte
Partner
Tax Controversy & Dispute Resolution
jlamotte@deloitte.lu
+352 45145 3336
Christelle Larcher
Managing Director
Tax Controversy & Dispute Resolution
clarcher@deloitte.lu
+352 45145 2976