Certainty in advance
Properly interpreting and applying tax rules can be a challenging task, and doubts and difficulties can arise. If left unaddressed, these can lead to disputes or even litigation in the future. In such situations, it is advisable to seek certainty in advance to avoid potential conflicts. We help taxpayers to request Advance Tax Rulings (ATRs) or Advance Pricing Agreements (APAs) from the tax authorities.
Tax rulings
An Advance Tax Ruling (ATR) is an official decision from a tax authority on how a particular transaction or situation will be treated for tax purposes. An Advance Pricing Agreement (APA), on the other hand, is an agreement between a taxpayer and the tax authorities on the transfer pricing method to be used for a specific transaction. We assists taxpayers in preparing and submitting their requests for ATRs or APAs, providing guidance on the relevant regulations and ensuring that the applications are complete and well-supported. Obtaining an ATR or APA can provide taxpayers with greater certainty and reduce the risk of potential disputes with the tax authorities.
We resolve and prevent your tax disputes
We help clients mitigate tax risks and resolve tax disputes. Our attorneys have experience in tax advisory, transactional tax and tax litigation and can help you manage your tax position and the tax position of your business. By working with us, you can optimize opportunities and minimize tax risks, leaving you with more time to focus on growing your business.