The audit powers of tax authorities can lead to complex requests, tax assessments, adjustments, penalties, and other administrative actions that directly impact a taxpayer’s tax position. In this context, a timely, consistent, and well-supported response—backed by advance preparation of supporting documentation—is critical to mitigating risks, preventing disputes from escalating, and preserving financial efficiency.
In recent years, there has been a growing sophistication in audit processes, as well as a greater divergence of criteria between taxpayers and tax authorities globally. This scenario requires the adoption of robust strategies from the early stages, based on rigorous technical analysis, proper evidence management, and a clear definition of the tax position.
Defining the strategy is the central pillar of the process. It is structured based on the nature of the case, the level of exposure, the procedural stage, and the taxpayer’s objectives. It may involve administrative proceedings before tax authorities, as well as defense in judicial proceedings when appropriate. Our approach integrates legal rigor with multidisciplinary technical analysis, incorporating—depending on the complexity of the case—elements of applied economics, transfer pricing, asset valuation, and financial modeling, with the aim of supporting robust and defensible positions.
Team and Experience
The service is led by senior tax attorneys with extensive experience in managing complex disputes at the local and international levels. The team combines a solid track record in advising large taxpayers with direct experience in tax audit procedures and tax dispute resolution. This dual perspective allows us to anticipate the authority’s criteria, structure effective defenses, and manage risks strategically.
Work Methodology
- Comprehensive background investigation and case diagnosis (facts, evidence, tax and financial implications).
- Organization and preparation of information to address requests from the tax authority.
- Analysis of regulations, case law, and legal doctrine; identification of contingencies and gaps in the case’s foundation.
- Definition of the defense strategy (administrative and/or judicial) and development of the case theory.
- Drafting, filing, and monitoring of briefs, appeals, and other procedural filings.
- Representation in administrative and judicial proceedings, including comprehensive management until the dispute is resolved.