Herreveld van den Hurk & Partners offers a unique combination of high level tax litigation support and international tax advice.
The ‘BEPS Actions’ results are finding their way to the multilateral and bilateral tax treaties while the EU directives like ATAD are being implemented in the national legal systems. This will potentially lead to many disputes and controversies with the local tax authorities. Most internationally operating companies will be confronted with a more aggressive attitude of the local tax authorities and potentially with tax disputes.
The results of the BEPS project of the OECD are finding their way into the multilateral and bilateral tax treaties, while EU directives like ATAD are being implemented in the national legal systems of EU Member States. Multinational companies will be confronted with a more aggressive approach by the local tax authorities on the bases of these changes. This will lead to many tax controversies and disputes with local tax authorities.
There are two major flaws in the defence against international tax claims.
The first is the absence of an international dispute resolution mechanism, making multinational companies dependent on local courts and mutual agreement procedures. The second is the limited knowledge of formal rules and litigation with the international tax advisors, and the limited knowledge of international tax with the local tax litigators.
Herreveld van den Hurk & Partners combines extensive knowledge in both areas.
With our knowledge we can help you prepare for discussions with the tax authorities, both in advance by investigating the possible flaws in the international tax structure and in case of a controversy, whether in the form of litigation, arbitration or mediation, by defining and executing a proper litigation strategy.