Tax Controversy

We are Stibbe Tax Controversy specialists

Supporting clients at all stages of a dispute, our experts bring a clear understanding of tax issues that can arise in controversies across many industries.

Tax Controversy

We work in close partnership with our clients to guide them through the complex challenges presented by tax controversies.

Our specialists handle all types of disputes with tax authorities both in court proceedings, in treaty-based arbitration and in the earlier stages of a conflict. As we recognise the benefits of resolving cases before litigation, we assist many clients with settlement negotiations, tax mediation and mutual agreement procedures. We have a keen awareness of the confidential nature of matters we deal with.

We handle all aspects of tax disputes including where third parties are being held liable for taxes, those involving international information exchange, fines, penalties, criminal tax law, and claims against the tax authorities in civil proceedings.

One of our unique specialisms is handling the tax aspects in civil litigation, for instance conflicts arising from the tax related clauses of share purchase agreements and other commercial contracts. In those matters we work in close cooperation with our corporate litigators.

In litigation, our experts have successfully represented our clients’ interests before all levels of the courts, including the European Court of Justice, the Belgian Constitutional Court, the Belgium’s Supreme Court (Hof van Cassatie/Cour de cassation) and the Netherlands Supreme Court (Hoge Raad).

Furthermore, should our clients be subject to investigations such as raids by the tax authorities, we provide decisive action and support.

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Related news

27.07.2021 NL law
Tax Controversy: Update July 2021

Short Reads - This Tax Alert addresses certain recent developments concerning procedural tax law in the Netherlands. We will discuss some interesting developments with regard to the (revised) Dutch tax ruling practice as per 1 July 2019 and the Tax Ruling Annual Report 2020. We will also discuss recent developments in case law regarding the abuse of law concept (fraus legis), and the possibilities to issue a fine to a taxpayer. Finally, we will also make some comments with regard to DAC6.

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15.07.2020 NL law
Emergency Act on Conditional Final Dividend Withholding Tax Levy submitted to Dutch parliament

Short Reads - On Friday 10 July 2020, a member of the Dutch opposition party Groenlinks has submitted an initiative legislative proposal for a Conditional Final Dividend Withholding Tax Levy Emergency Act (the 'Proposal') to Dutch parliament. The Proposal provides for a conditional final Dutch dividend withholding tax ('DWT') levy due in the event of certain cross-border reorganizations.

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09.03.2021 NL law
Consultation on ATAD 2 (reverse hybrids) and amendment arm’s-length principle in the Netherlands

Short Reads - As noted in our earlier Tax Alerts (see our Tax Alerts of March 2017 and July 2019), the EU Anti-Tax Avoidance Directive 2 ("ATAD 2") provides for minimum standards to neutralize hybrid mismatches and came into effect in the Netherlands as of 1 January 2020. However, as an exception, the rule that targets so-called “reverse-hybrid” mismatches will become effective only as of 1 January 2022.  

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24.09.2020 BE law
Stibbe hosts a webinar on dawn raids organised by IBJ/IJE

Seminar - On 24 September 2020, several Stibbe lawyers ​​​​​explain the rights and obligations of companies when confronted with announced or unannounced raids. What do to when, for example, tax authorities, the competition authorities, police services or a bailiff are at your doorstep?

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21.05.2020 NL law
Stibbe 'Netherlands Tax Firm of the Year'.

Inside Stibbe - The International Tax Review has chosen our Amsterdam Tax team as 'Netherlands Tax Firm of the Year'. This is Stibbe's fourth recognition in recent years, after receiving this distinguished title in 2015, 2017 and 2019.

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