Tax Expert Services
Accounting and tax examination of assessments, credits, tax bases and amounts in dispute in court and administrative proceedings.
Overview
The tax dispute is legal. The amount at stake is technical.
In tax disputes, a legal argument only has effect when the numbers support it: tax base, credits, calculations and effects in each period. SGEx examines accounting and tax records, ancillary filings and supporting documents, as court-appointed expert or as party-appointed expert, in judicial and administrative proceedings.
When clients call on SGEx
- Defences and appeals against tax assessments in administrative proceedings.
- Tax enforcement actions, objections and annulment actions involving disputed amounts.
- Tax refunds, offsets and determination of credits recognised in a decision.
- Disallowance of PIS, Cofins, ICMS or IPI credits.
- Disputes over corporate income tax (IRPJ and CSLL), tax base and adjustments.
How SGEx works
- Records as evidence. Accounting and tax books, SPED files and supporting documents compared with the assessment.
- Period by period. Each tax period determined separately, with the source of every difference identified.
- Calculation by argument. Where the dispute is legal, each argument is quantified for the decision-maker.
Expert work does not replace the legal argument: it shows what it is worth and whether the records support it.
What We Solve
- Is the assessed tax base correct? Rebuilding the base from the accounting records and tax documents.
- Are the disallowed credits supported? Examining documents, the nature of expenditures and their link to the activity.
- What is the recognised credit worth? Determining refunds and amounts to offset, with updating.
- Are the records consistent? Cross-checking accounting, SPED files, tax returns and tax documents.
- Is the amount under enforcement correct? Reviewing the certificate of tax debt and the additions charged.
- What is the effect of each argument? Quantifying the tax effects of each criterion in dispute.
How We Approach It
Assessment and questions
Defining the facts, periods and taxes in dispute.
Records
Gathering books, SPED files, tax returns and tax documents.
Rebuilding
Determination by period and by criterion, with calculation workpapers.
Report or opinion
Direct answers, differences identified and supporting exhibits.
What we examine
Tax assessments and administrative decisions, certificates of tax debt, accounting and tax records, SPED files (ECD, ECF and EFD), tax returns, invoices and contracts.
Possible Deliverables
The format is defined according to the agreed scope and the purpose of the work.
- Expert report
- Technical opinion
- Rebuilding of tax bases and credits
- Refund calculation
- Answers to questions
- Technical critique of expert reports
Other SGEx Solutions
Services, specialties, contexts and industries connected to this topic under SGEx's relationship matrix.
Related Services
- Accounting Expert ExaminationIndependent expert examination of accounting records, financial statements and calculations, prepared for judicial, arbitral and administrative proceedings.
- Forensic AccountingReconstruction and examination of accounting records and financial flows for evidentiary purposes, in contexts of suspected wrongdoing, conflict or inquiry.
- Court Calculations and Accounting SupportPreparation, review and challenge of court calculations for law firms, companies and organisations, with validation technology and high-volume production.
- Criminal Forensic AccountingAccounting and financial examination of facts under investigation in criminal and administrative sanctioning proceedings, for those who accuse and those who defend.
Related Specialties
- Tax MattersLoss of tax immunities and benefits, enforcement and challenge of tax assessments, contingencies and review of calculations.
- Forensic Accounting and AuditAccounting reconstruction, tracing of financial flows, analysis of financial statements, contingencies and fraud investigation.
- Judicial Reorganization, Bankruptcy and InsolvencyPreliminary expert examination, verification and challenge of claims, asset valuation, insolvency and liquidation.
- Expert Assistance to PartiesExpert assistance to parties in court-appointed expert examinations and arbitrations: framing expert questions, opinions, review of reports and attendance at proceedings.
- Administrative ProceedingsAccounting and financial expert evidence in administrative tax, sanctioning, regulatory and oversight proceedings, from the defence to the appeal stage.
Related Areas of Practice
- Tax Litigation and Administrative ProceedingsTax controversies in judicial and administrative proceedings that turn on accounting evidence and the review of tax calculations.
- Corporate Criminal MattersCriminal proceedings involving companies and their officers in which the evidence turns on accounting and financial analysis.
- Corporate and Shareholder DisputesDisputes among shareholders, partners and officers, corporate dissolutions, buyout claims and disagreements over financial results.
Related Industries
- Industry, Manufacturing and Consumer GoodsManufacturers and consumer-goods producers involved in valuations, and in commercial, tax and corporate disputes.
- AgribusinessProducers, cooperatives, trading companies and agro-industrial businesses involved in valuations, succession matters and judicial reorganization.
- Energy and Natural ResourcesPower generation, transmission and distribution, oil, gas and mining, involving long-term contracts and regulatory disputes.
- Pharmaceuticals and Drug DistributionPharmaceutical manufacturers, distributors and retail chains involved in commercial, tax and accountability disputes.
Talk to our specialists
Send the assessment or decision, the periods involved and the records available. SGEx will assess the scope before submitting any proposal.