- building “defence strategies” into the relevant transaction
- ensuring documentary evidence supports the purpose and steps of the transaction;
- Negotiating pre-filing rulings, including unilateral agreements, Advance Pricing Agreements, and accelerated Competent Authority / Mutual Agreement Procedure negotiations;
- pro-actively negotiating with the tax authorities or seeking “clearance” at the pre-audit stage to gain earlier certainty and achieve penalty protection;
- engaging with tax authority cooperative compliance programmes;
- assisting in transactional due-diligence to identify tax audit and controversy risks and exposures; and
- developing and implementing solutions following the identification of risks
Taking proactive steps before an audit or dispute begins