Factual Agreements

Coming to “watertight” agreements with the Tax Authorities. We assist you as tax law specialists and defence attorneys in Cologne.

Complicated circumstances and continuously changing, non-transparent tax law have an inherent potential for conflict: At the time of a transaction taking place, company owners and individuals are often unaware of the taxation ramifications of their conduct. The issue boils to the surface only amid a company tax audit taking place a long time later, because the tax auditor holds suspicions about certain circumstances in relation to tax. The person affected was unaware of the specific nature of the situation at that time, and did not deem it necessary to record the facts or secure evidence. In such a case, where the actual occurrence of a factual situation is disputed between the Tax Authority and the taxpayer, the latter is faced with the question if he can withstand the pressure exerted by investigations, if he is able to assist under his duty to cooperate or whether there might not be a better way of resolving the situation. Clients often seek to enter into so-called factual agreements with the Tax Authority and our tax law specialists will arrange for this to happen in a “watertight” way.