In order to deal with tax controversy effectively, all parties should use the same vocabulary.
CLICK HERE for a ‘list with definitions’ often used in case of a tax litigation or mediation or simply in case of a dispute between parties on tax matters. The GTC team is involved in a continuous dialogue with all stakeholders of tax disputes, to make sure a discussion based on ‘arguments’ is facilitated.
The GTC team has an extensive experience and knowledge sharing platform, which is used to facilitate all parties involved in these cases, which includes for example:
- Technical analysis on static versus dynamic interpretation of existing tax treaties;
- How does the multi-lateral instrument (MLI) under BEPS work on ‘real facts’;
- How EU definition on ‘state aid’ impacts the ‘at arm’s length’ standard;
- Standards for using an ‘attorneys privilege for non-disclosure’;’
- Standards for obtaining arbitrage in cases of ‘double/triple/quadruple tax paid’;
- Summaries of most relevant court cases on tax matters;
- Formal procedures for APAs, MAPs etc;