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Factual Agreements in Tax Law and Criminal Tax Law

How to enter into “watertight” settlements with the Tax Authority. We assist you as tax law specialists (tax attorneys) and defence lawyers in Cologne.

Complicated circumstances in life and continuously changing, obscure tax laws bear the potential for conflict: A company owner or individual is frequently unaware of the tax consequences entailed by his conduct. The issue boils to the surface when faced with a company tax audit at a later stage, because the auditor suspects certain tax-relevant circumstances. The taxpayer was however guileless at the time of his specific conduct and did not deem it necessary to document the facts or secure evidence. In such a case, where facts are disputed between the Tax Authority and the taxpayer, he faces the question whether he can withstand the pressures exerted by investigations, whether he can clarify the facts in light of his duty to cooperate, or if there might not be a better way for him. Clients frequently desire to settle such issues by entering into so-called factual agreements with the Tax Authority. Our tax law specialists in Cologne will work towards a comprehensive and “watertight” implementation of this desire.

1. What is a factual agreement?

2. Mandatory formal requirements

3. When can a factual agreement be entered into?

4. What special rules apply in criminal tax proceedings?

5. What renders factual agreements invalid?

LHP: Attorneys at Law, Tax Law Specialists, Tax Advisers PartmbB


An der Pauluskirche 3-5, 50677 Cologne,
Telephone: +49 221 39 09 770


Tödistrasse 53, CH-8027 Zurich,
Telephone: +41 44 212 3535

Auszeichnungen & Zertifikate als Steuerkanzlei - LHP Rechtsanwälte