42 · Tax · Contrôle & juridictions
Tax litigation
What assistance changes in this practice, what it does not change, and the time reduction actually observed.
Where the gain is real
Reconstruction of the positions taken year by year, preparation of responses to requests, research into the applicable guidance and case law.
Where it is slight or nil
Meetings with the inspector, the tax commission, the hearing.
Observed time
−46% at constant case scope, on cases closed over the last three financial years. This measure says nothing about the quality of the outcome.
What the practice covers
- Reconstruction of the tax positions taken, year by year
- Preparation of responses to information requests and to reassessment notices
- Research into the applicable administrative guidance and case law
- Transfer pricing: consistency between documentation, contracts and actual flows
- Checking of the assessment periods and of what interrupts limitation
- Quantification of the reassessment, interest and penalties at stake