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Nexia Ebner Stolz

Tax Advice

Tax Disputes and Criminal Tax Cases

When cash is short, both si­des – the tax of­fice and the tax­payer – of­ten go for broke. Com­pro­mi­ses are hard in such ca­ses, so that ap­peals and tax suits are be­com­ing more and more im­port­ant. And with good re­ason from the stand­point of tax­pay­ers and their ad­vi­sors: over the past few years, two-thirds of all Ger­man tax ap­peals have suc­cee­ded ent­irely or at least in part. The same goes for al­most half the ac­tions brought in tax courts. Ap­peal pro­cee­dings de­pend ent­irely on a care­ful pre­pa­ra­tion of the case and the as­so­cia­ted le­gal ques­ti­ons. That ta­kes a tho­rough un­der­stan­ding of tax law, but also prac­tical ex­pe­ri­ence in hand­ling pro­cee­dings in tax court. A spe­cial know­ledge of pro­ce­dure is nee­ded for ap­peals to the Fe­deral Tax Court, or for com­plaints against the de­nial of leave to ap­peal.

In our con­sul­ting on tax dis­pu­tes, we pro­tect your in­te­rests and rights against the tax ad­mi­nis­tra­tion. If in­ten­sive dis­cus­sions with the tax ad­mi­nis­tra­tion can’t re­ach an agree­ment, we’ll ma­nage your ap­peal to the tax of­fice and any sub­se­quent ac­tion in tax court. Thanks to our ex­ten­sive ex­pe­ri­ence in hand­ling ap­peals and com­plaints to the Fe­deral Tax Court, we can ad­vise you ho­nestly and fran­kly about your pro­spects for suc­cess, and of course we can also re­pre­sent you be­fore Ger­many’s su­preme tax aut­ho­rity. As a last re­sort, fi­nally, we can con­sider an ap­peal to the Fe­deral Con­sti­tu­tio­nal Court.

The boun­da­ries bet­ween le­gal tax struc­tures and il­le­gal tax eva­sion can so­me­ti­mes be fluid, and hard for a lay­per­son to iden­tify. While tax eva­sion still coun­ted as a mi­nor of­fense just a few years ago, the wind now blows col­der in cri­mi­nal tax law. In va­lue ad­ded tax and em­ployee wi­th­hol­ding tax es­pe­cially, busi­ness peo­ple who are ent­irely una­ware of vio­la­ting the law may still be tar­ge­ted for a tax in­ves­ti­ga­tion. Even when there’s no cri­mi­nal con­duct, ad­mi­nis­tra­tive of­fen­ses can of­ten lead to pain­ful fi­nes. If tax ob­li­ga­ti­ons ha­ven’t al­ways been trea­ted with the grea­test care in the past, there’s still the pos­si­bi­lity – for now – of volun­ta­rily com­ing for­ward and qua­li­fy­ing for am­nesty. In all these ca­ses, it’s es­sen­tial to act with cau­tion and ex­pert ad­vice.

We can as­sist you with every as­pect, from va­lidly com­ing for­ward to ac­tual cri­mi­nal tax pro­cee­dings. Our tax la­wy­ers have not only the ne­cessary tax know­ledge, but the ne­cessary know­ledge of cri­mi­nal law and cri­mi­nal pro­ce­dure. To keep pro­cee­dings on cri­mi­nal or ad­mi­nis­tra­tive of­fen­ses from ever hap­pe­ning in the first place, we of­fer you all-in­clu­sive pre­ven­tive con­sul­ting, and can point up po­ten­tial weak spots in your com­pany.

Our services at a glance

  • Ap­peal pro­cee­dings at tax of­fices
  • Ac­tions in tax court
  • Ap­peal pro­cee­dings and com­plaints against de­nial of leave to ap­peal in Fe­deral Tax Court
  • Con­sti­tu­tio­nal com­plaints to the Fe­deral Con­sti­tu­tio­nal Court
  • Volun­ta­rily com­ing for­ward
  • Re­pre­sen­ta­tion in cri­mi­nal and ad­mi­nis­tra­tive tax pro­cee­dings
  • Pre­ven­tive con­sul­ting

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