Resolution of tax disputes

We identify fiscal risks and mitigate possible future controversies from the national and international perspective

 

In recent years, numerous countries have entered into tax information exchange agreements between governments, which has allowed them to share, collect and collate that of those taxpayers who operate in various jurisdictions, resulting in a more rigorous environment in terms of control and tax policies. Today, the tax effects that occur in one jurisdiction can have an immediate impact in another country, especially in the case of multinational groups, which are usually subject to a high level of scrutiny by global tax authorities to verify full compliance. of their tax obligations. Derived from this, the opportunity arises to prevent conflicts through a Tax Dispute Resolution scheme, prior to a contentious process, which becomes an extremely beneficial tool for those taxpayers who may face or be exposed to an Audit process by the tax authorities. Our services focus on identifying tax risks from a local perspective and, also, from an international perspective, seeking to mitigate possible future controversies to which organizations may be exposed. In case of being subject to audit processes, we promote relevant alternative means that contribute to its resolution, through the facilitation of communication and exchange of information between tax authorities and taxpayers.

 

MAIN SERVICES

  • Advice on the development and implementation of Transfer Pricing policies
  • Establishment of best financial and tax practices appropriate to each industry
  • Analysis of Transfer Pricing information, for the purposes of promoting due compliance at the local and international level
  • Preparation of defense files to support with sufficient information the operations carried out with companies of the same Group
  • Assistance in reviewing or drafting agreements or intercompany agreements
  • Promotion before the Mexican and foreign tax authorities of alternative means of dispute resolution such as: advance agreements on unilateral Transfer Pricing (APA), bilateral (BAPA) and friendly procedures (MAP).
  • Accompaniment in the establishment of powers of verification by tax authorities of any level of government so that, as far as possible, the contingencies for which they are responsible are reduced
  • Approach with the administrative authorities to optimize the understanding and response to the observations made by them
  • Promotion of alternative means of local dispute resolution (Conclusive Agreements) before the Taxpayer Defense Attorney’s Office (PRODECON)
  • Promotion of means to safeguard the tax rights followed before PRODECON, such as Complaints, or queries to obtain a confirmation issued by said agency confirming the operation of the company
  • Preparation of real and specific queries before the tax authority of any level of government