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Tax Audits & Internal Investigations

Building the Record Before Positions Become Fixed

Averites represents companies, shareholders and private clients in tax audits, administrative proceedings, litigation and other disputes with tax authorities.

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OUR APPROACH

How We Advise on Tax Audits and Internal Investigations

  1. Why Tax Disputes Increasingly Turn on Substance

    Tax disputes can arise from disagreements concerning the interpretation of law, but they increasingly turn on questions of substance, beneficial ownership, transfer pricing, residence, permanent establishment and whether the factual operation of a business corresponds to its legal documentation.

  2. Getting Involved From the Earliest Stages

    We advise clients from the earliest stages of a tax inquiry or audit, helping establish the factual and legal record before positions become fixed.

  3. The Range of Disputes We Handle

    Our work includes disputes concerning corporate income tax, VAT and indirect taxes, withholding tax, transfer pricing, related-party transactions, permanent establishment, tax residence and other domestic and cross-border tax matters.

  4. From Information Requests to Court Proceedings

    We assist with responses to information requests, preparation of legal submissions, challenges to tax assessments, administrative appeals and court proceedings.

  5. Working With Accounting and Valuation Experts

    Where complex accounting, valuation or economic questions arise, we work with accountants, auditors, transfer pricing specialists and other experts to develop the evidentiary record supporting the client’s position.

  6. When a Tax Investigation Creates Exposure Beyond Tax

    Tax investigations may also create exposure outside the tax proceeding itself. Allegations of false transactions, misuse of corporate structures, tax evasion, or improper payments can result in criminal, regulatory, reputational, or shareholder consequences.

  7. Coordinating Strategy Across Tax, White Collar and Disputes

    In those circumstances, our Tax, White Collar and Dispute Resolution teams coordinate the strategy across relevant proceedings. Positions taken before tax authorities are considered alongside potential criminal or civil exposure, so that the client does not resolve one immediate issue at the expense of a greater risk elsewhere.

  8. Negotiated Resolution Where Appropriate

    Where appropriate, we also advise on negotiated resolution, settlement and remediation strategies.

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Precision across borders. Book a Meeting

New York c/o Chornous Law PLLC
30 Wall Street, 8 Floor
New York, NY 10005 Phone: +1 650 382 7764
London 124 City Road
London, England
EC1V 2NX Phone: +44 7405 138109
Kyiv 11 Panasa Myrnoho Street
Office 1/1
Kyiv, 01011 Phone: +380 63 148 27 37

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FAQ

Frequently Asked Questions

  • Tax disputes can arise from disagreements concerning the interpretation of law, but they increasingly turn on questions of substance, beneficial ownership, transfer pricing, residence, permanent establishment and whether the factual operation of a business corresponds to its legal documentation.

    • As early as possible. We advise clients from the earliest stages of a tax inquiry or audit, helping establish the factual and legal record before positions become fixed.

      • Our work includes disputes concerning corporate income tax, VAT and indirect taxes, withholding tax, transfer pricing, related-party transactions, permanent establishment, tax residence and other domestic and cross-border tax matters.

        • Yes. We assist with responses to information requests, preparation of legal submissions, challenges to tax assessments, administrative appeals and court proceedings.

          • Yes. Where complex accounting, valuation or economic questions arise, we work with accountants, auditors, transfer pricing specialists and other experts to develop the evidentiary record supporting the client’s position.

            • Yes. Allegations of false transactions, misuse of corporate structures, tax evasion, or improper payments can result in criminal, regulatory, reputational, or shareholder consequences beyond the tax proceeding itself.

              • Our Tax, White Collar and Dispute Resolution teams coordinate the strategy across relevant proceedings. Positions taken before tax authorities are considered alongside potential criminal or civil exposure, so the client does not resolve one immediate issue at the expense of a greater risk elsewhere.

                • Where appropriate, we also advise on negotiated resolution, settlement and remediation strategies — our focus is to protect the client’s substantive position while maintaining a clear view of the broader commercial consequences of the dispute.