The adversarial procedure: a right that belongs to you
Receiving a proposed reassessment is often an ordeal. The tax authorities may claim substantial sums from you, together with surcharges and late-payment interest. This proposal is not, however, a final decision: you are entitled to challenge its grounds and consequences where it appears to you to be unjustified, unfounded or disproportionate.
Identify the grounds of challenge and assess the strength of the proposed adjustments.
Define a defence strategy suited to your situation
Ensure compliance with the procedure and the applicable time limits
Represent you in your exchanges with the tax authorities
Preserve your rights with a view to possible litigation
Four stages to defend your interests effectively
We examine the proposed reassessment line by line in order to assess whether the sums claimed are well founded, verify that the procedure followed by the tax authorities was lawful and identify the legal and factual arguments that may be raised against it.
Before any drafting begins, we discuss matters with you in order to define a position consistent with your situation and objectives. We then prepare documented and reasoned observations, drawing on the applicable legislation, the tax authorities' published guidance and the case law relevant to challenging the proposed adjustments.
If the tax authorities reject our observations, we examine the reasons for their response carefully and determine how the challenge should proceed. Where the circumstances warrant it, we refer the matter to the inspector's line manager in order to continue the adversarial dialogue and seek a favourable outcome.
Where the nature of the disagreement allows, we assess whether to refer the matter to the competent commission, which, depending on the subject matter, is made up of judges, representatives of taxpayers and of the tax authorities, and qualified professionals. We prepare the file submitted for its review and defend your arguments at the hearing in order to obtain a favourable opinion likely to influence the rest of the procedure.
Private individuals, directors and businesses seeking a tailored defence
Every case calls for a tailored defence strategy, built around what is at stake and the client's situation. Our approach nevertheless remains the same: legal expertise, commitment and tenacity.
