Working Session 9

The international differences in the communications with the tax authorities, both preliminary/consultative and contentious

Tax authorities – surely each one of us had the pleasure to deal with one: as taxpayer at least with the tax authority of the country you are resident of, as a lawyer helping others in tax matters you might have had the chance to deal with the tax authorities of other countries as well. If the latter is the case you might have seen some differences in the behaviour of the different tax authorities. You might have realized that the tax authorities in some or even the majority of the countries do treat the taxpayers not as their customers or clients but rather as subordinates.

In such cases the communications tends to be rather hierarchical and often results in administrative proceedings against the tax authorities with more or less success.

Other countries have realized that treating the taxpayer in ways like we know from the tale of Robin Hood and the Sheriff of Nottingham only results in the tax payers trying to circumvent their tax obligations. Some countries, thus, have not only reduced the taxes in their countries. They also made their tax authorities treat the taxpayers as their clients e.g. in offering the taxpayers the possibilities for tax rulings and trying to take a more tailored approach towards their taxpayers.

These – sometimes very significant – differences are what we are focusing on in this year’s tax report: We want to show that there are big distinctions in the behaviour of and the dealing with the tax authorities in different countries both in the stage of an advance agreement on a tax position as well as in an objection or litigation phase.

General Reporters:

Christian Presoly, Batliner Gasser, Liechtenstein
Gustavo Yanes, Monereo Meyer Marinel, Spain

Speakers:

Claude Aemisegger, Homburger, Switzerland
Jessica Dabbs, Withers LLP, United Kingdom
Gerardo Diaz, Basham, Ringe y Correa S.C., Mexico
Dina El-Gazzar, Bedell Cristin, United Kingdom
Alain Goebel, Arendt & Medernach, Luxemburg
Johan Myren, Advokatfi rman Lindahl, Sweden
Elina Putnina, Rödl & Partner, Latvia
Egon Talur, Borenius, Estonia
Ayse Ülkü Solak, Moroglu Arseven, Turkey
Martinos Typographos, Typographos & Co lawyers, Cyprus

COMMISSION: Tax Law

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GENERAL REPORTERS