Tax audits and tax disputes

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The Tax & Structuring team stands out in highly complex cases and processes. We have extensive experience in tax disputes where precedent is important and we are also highly experienced in advising clients during tax audit processes. In addition to disputes and audits related to corporate tax and transfer pricing, our team is regularly involved in disputes and audits covering customs, excise, and VAT.

Due to our extensive experience with a variety of tax disputes, our lawyers understand the importance of strategy: Choosing the right defense strategy is a key success factor when resolving tax disputes. Our team is also known for making the relevant legal questions stand out without sacrificing the meaning of details. We collaborate closely with the firm's Dispute Resolution practice in preparation for oral hearings.

Handling tax disputes calls for a deep business understanding as well as an ability to communicate legal issues to authorities and courts in a comprehensible manner. The successful handling of disputes also requires that the facts of the case can be supported by sufficient evidence. In addition to factual questions, our involvement in various tax litigations recently has required increased attention to complex procedural questions.

Roschier is currently advising clients in a number of high-profile tax audits and disputes. The total interest involved in these ongoing cases is close to EUR 1 billion. These matters relate to issues such as:
  • Consideration payable between related parties in connection with restructurings of business models
  • Transfer pricing disputes
  • Applicability of anti-avoidance rules in acquisition structures and various other situations
  • Applicability of Finnish interest barrier rules in various structures
  • Taxation of trust income
  • Allocation of assets and related liabilities between head offices and Finnish branches
  • Interpretation of the recently implemented new rules in the Transfer Tax Act
  • Interpretation of customs and excise duty rules