
Tax Dispute Resolution
Technological tools have transformed the way tax authorities collect information and monitor taxpayers. They constantly develop new programs for inviting and sending tax requests, which turn into audits that lead to legal disputes.
At CB Strategy, we support our clients in initiating and maintaining open, ongoing, and direct relationships with tax authorities, with the goal of minimizing risks and disputes.
We have strategies, mechanisms, alternatives, and tools that provide creative and agile solutions to tax disputes that may arise. We seek to promote and implement best tax practices within our clients' companies and resolve problems arising from communication errors, incomplete information, and economic and political pressures. Some of the services we offer include:
- Identification, evaluation and quantification of tax risks.
- Design and implementation of fiscal risk remediation and mitigation strategies.
- Assistance to taxpayers listed in Article 69-B for alleged simulated operations.
- Strategic analysis of vulnerable operations.
- Handling invitation letters, requests, summonses, and procedures from tax authorities.
- Consulting on the development and implementation of corporate policies regarding tax risks.
- Establishment of financial and tax best practices appropriate to each industry.
- Preparation of supporting files for controversial operations.
- Preparation, analysis and review of intercompany contracts.
- Dispute resolution under international treaties in transactions with non-residents.
- Obtaining favorable balances by exhausting legal procedures.
- Support and strategic advice on audits and requirements.
- Approach and negotiation with tax authorities before and during the audit.
- Preparation of real and concrete inquiries (resolutions) before the tax authorities and the Taxpayer Defense Office.
- Interposition of alternative dispute resolution methods, such as unilateral advance pricing agreements (APA), bilateral advance pricing agreements (BAPA) and amicable settlement procedures (MAP).
- Drafting conclusive agreements before the Taxpayer Defense Office.
- Filing of appeals for revocation.
- Filing of nullity lawsuits.
- Filing of amparo lawsuits.

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