PT EN
Area of Practice

Tax Litigation and Administrative Proceedings

In tax assessments, tax-enforcement actions and tax litigation, the legal debate over whether a given tax applies eventually comes down to accounting evidence: the tax base, credits taken, how revenue was classified, and the amount actually owed.

In Summary
Tax controversies in judicial and administrative proceedings that turn on accounting evidence and the review of tax calculations.

Context of application

A company's tax and accounting records are voluminous and spread across ancillary filings, ledgers and different systems. Technical analysis organizes these sources so that the discussion over the tax credit rests on verified figures.

When this analysis is needed

  • Objections and appeals filed in administrative tax proceedings.
  • Tax-enforcement actions and related objections that turn on disputed amounts.
  • Claims for the refund of amounts unduly paid and tax offsets.
  • Loss of tax immunities and tax benefits.
  • Accounting expert examinations conducted in tax proceedings.

Questions typically analyzed

  • Review of tax calculations.
  • Enforcement and challenge of tax credits.
  • Determination of tax contingencies.
  • Loss of immunities and of tax and fiscal benefits.
  • Reconciliation between the bookkeeping and ancillary tax filings.

How SGEx Approaches This

SGEx reconstructs the tax base under discussion from the company's own records, compares it against the assessment or the calculation presented by the tax authority, and records every difference by nature and by period.

SGEx does not provide legal advice. Its contribution is technical: organizing the economic, financial, accounting and asset-related facts so that lawyers, companies and parties can understand the substantive dimension of the controversy.

Steps in the SGEx methodology

Possible Work and Deliverables

The format is defined according to the case, the proceeding and the purpose of the work.

  • Tax-accounting expert opinion
  • Recalculation of tax credits
  • Expert report
  • Expert questions
  • Contingency report
Knowledge Network

Other SGEx Solutions

Services, specialties, contexts and industries connected to this topic under SGEx's relationship matrix.

Next Step

Request an Analysis

Describe the technical question, the context in which it arose, and the documents available. This information lets SGEx assess the scope of the work before any proposal.