We find or create a path forward in all phases of potential or actual tax-related disputes. This includes advance certainty (rulings), audits and reviews, litigation, mutual agreement and settlements and their implementation. We operate in an international context for businesses, private clients and non-profit organizations.
In most situations, we build bridges through integrative negotiation with tax authorities.
It is essential to take an open-minded approach questioning not only arguments, but also underlying rationale and intentions of both sides. We adopt the Harvard-style and are convinced that this creates surprising opportunities for synthesis and new solutions.
The solution to reviving a bogged-down conversation is to pluralize, to add frames and meaningful perspectives, to make the debate multi-coloured. If you merely stick to your arguments, remain colour-blind and dig in, you will not get anywhere.
We are convinced a solid bridge in international tax issues can only be built on a foundation of clear and sincere communication, trust and understanding. For our work and our clients to remain relevant, whilst putting their interests first, we also keep an eye on interests of other stakeholders in society.
Some fundamental, principled matters are as such not fit for negotiation. For such principled issues that need to be decided in court, we will negotiate a framework for an efficient and strategic litigation on principled points. We hold the key to effective case management through communication and curiosity to understand the tax man’s views. Such case management can still lead to a settlement if these principles change midway through in a different context.
Only in rare situations, we would need the decision of the Supreme Court or Court of Justice of the European Union on legal principled questions; this takes a lot of effort, stamina and costs and the outcome is increasingly uncertain. Nonetheless, some cases requires this kind of investment in order to change things.