Why European human rights are increasingly important in tax disputes 

In my student days a couple of decades ago, we were taught that the law always needs explanation and is never self-evidently clear. After all, it is impossible for a law to be clear in all cases in practice. There are numerous ways of interpreting the law, in which conscience always plays an important role in the context of a “reasonable interpretation” of the law. Officials and judges, in this view, are never literalists, but always use their full intellect and conscience. 

In these times of polarization, pressure and the accompanying culture of fear, I unfortunately see and hear more and more statements such as ‘the law does not allow us to do otherwise’ or ‘this is just the law’. In the public discourse, the Toeslagenaffaire or childcare benefits scandal has brought to light that our highest administrative judge believes that legal certainty, as the result of consistent application of the law, is the opposite of “customization”. For example, in its reflection report on the Toeslagencrisis, the Council of State observed that the administrative judge ‘is increasingly expected to find a good middle ground between uniformity and customization in his rulings’. 

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Five best practices in Dutch tax litigation

According to some, litigation is an art. Others, including me, might say it is a craft. Sure, we all need inspiration, perseverance and creativity to get to a good result. In the end, however, it is experience and method that will get us there. Below we explore five best practices to reflect this.

1. Convince the court, not the counterparty

In litigation, clients and counsel must resist the natural urge to try and convince the opposing party. Whether you’re up against the authorities, another legal person or individual or the public prosecutor, immediately before the litigation phase started, you were trying to reach an understanding with the ‘other party’. You were trying to make them see your point, win them over and avoid litigation. Apart from ‘them’ being convinced of your point, many other factors could have lead to a compromise or even an all-out win for your side. Policy, lack of means or priority, the personality of the official, procedural mistakes, the kindness of their hearts, if you will. It could all have played a role. Once they’ve decided to reject a claim and the case escalates to the judicial chain (first instance, appeal and cassation, in the Netherlands), it’s goodbye to most of that.

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