Our tax lawyers have substantial experience in audit representations and have an impressive track record of successfully compelling tax authorities to withdraw from or compromise on audits with respect to Corporate Tax, Income Tax, Consumption Tax (VAT), Customs Duty, Inheritance Tax, Gift Tax and other taxes.
Although the optimal result in audits is to induce the relevant tax authority to withdraw from or compromise on an audit, it is sometimes necessary to file an administrative appeal with the relevant tax tribunal. Our tax lawyers have extensive appellate experience and have been successful in appeals on a wide range of matters, including transfer pricing issues and corporate reorganizations.
Taxpayers and tax authorities frequently take different views on tax issues. Anderson Mori & Tomotsune has a remarkable track record of successfully representing taxpayers in tax litigation over a broad spectrum of matters.
- Negotiations with Tax Authorities
AM&T has considerable experience in representing clients in negotiations with tax authorities in connection with audits and other similar situations.
- Our representative experience includes the following:
- Successfully overturning a tax authority ruling that had disallowed a depreciation deduction in a lease structure involving the lease of certain assets through an offshore limited partnership;
- Successfully representing a client in tax litigation challenging a tokumei kumiai (silent partnership) transaction; and
- Advising on a complex transfer pricing application audit involving intangible assets.