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Obtaining and correctly adhering to a ruling after an agreement’s reached with the authorities can take a significant amount of time and resources. Your treatment of the transaction in question must align with the ruling over time, at the risk of complications in case of an audit.
Things can change, so what if your post-ruling processes don’t exactly correspond with the terms of the ruling? In this case, you need to either adjust the implementation to align with the ruling, or your need to inform the tax authorities of the changes and reconfirm the tax treatment agreement.
We help you prepare a ruling, propose it to the tax authorities and obtain agreement on the tax treatment of a particular transaction, based on the underlying business facts. A key aspect of our approach lies in our post-implementation support: one year later, we validate that your actions correspond to the ruling. If your process has changed, or transactions were implemented differently, we take the necessary steps to either help you adjust your implementation accordingly or revise the ruling.
The legal certainty that accompanies a ruling helps you control your organisation’s overall tax burden.