Tax appeal and ruling request assistance

Tax controversy and dispute resolution

The complexity and convergence of economic phenomenon has recently resulted in a substantial increase in the number and size of disputes with revenue authorities over the interpretation and enforcement of laws during the course of tax assessment and payment. This situation puts it in a high priority to develop a persuasive rationale to address a client’s complex problems and facilitate communications with the revenue authorities to its best advantage.

Our experience encompasses a broad spectrum of industries and extensive knowledge resources of dispute issues, relevant laws and regulations of respective industries in which our clients operate. This enables us to formulate industry-specific and issue-specific solutions and develop focused strategies to cope with the tax authorities’ challenge so that the successful dispute resolution is ensured.

Application for ruling

Assistance with the application for rulings is designed to reduce various tax risks by obtaining a written ruling from the tax authorities if a certain tax compliance of taxpayers is affected by uncertainties. By obtaining a ruling from the revenue authorities, companies can proactively prevent and reduce uncertainties of a prospective business so as to promote the efficiency and confidence of a management decision. It also enables for a company to realize opportunities for refund of overpaid tax through the application for reassessment or tax appeal.

Samil PwC professionals are highly experienced in tax risk analysis, pre-audit tax reviews, tax appeals, mergers and acquisitions, split-offs, reorganizations and other business advisory consultations as well as technical researches which can differentiate us from competitors.

How we can support you

Tax controversy resolution
  • Understand issues challenged by the tax authorities, dispute issues and relevant facts, and review logics applied by the tax authorities.
  • Assist with the development of a persuasive rationale for an appeal through in-depth review of relevant laws, regulations and court rulings
  • Assist with the preparation of a statement of case in tax appeal and submission of supporting documents for pre-assessment protest to relevant authorities throughout the appeal process.
  • Facilitate communications and logical appeals with the relevant government authorities 
Application for ruling
  • Identify tax issues that require the clearance and certainty by applying a ruling from the relevant tax authorities.
  • Evaluate and quantify the tax effect involving the identified tax issues and develop logics in pursuit of obtaining a favorable ruling.
  • Assist with the preparation of documents to apply a ruling and the explanation of facts and circumstances as well as issues in dispute to the relevant authorities.
Follow us