The complexity and dynamism of the tax legislation and the increase in the acts of control have made it more common to have the need of subjecting the actions of the tax authorities to judicial oversight.

Among the services we offer in the contentious area is refuting:

-Resolutions to determine a tax liability.

-Resolutions denying the return of a contribution.

-Resolutions to determine the transfer pricing of a transaction.

-Resolutions in which a treaty is improperly applied in order to avoid double taxation.

-Resolutions in which an international treaty on trade is improperly applied.

-Acts Issued within the tax collection proceeding.

-Prejudgment attachment or coercive measures.

-Other Acts causing grievance in matter of taxation.

In this contentious area, our experience, expertise and personal attention become defining attributes that we put at your fingertips.

The constant fiscal reforms to which our jurisdictional system is subject to, have as consequence the execution of tax rules that can weaken the constitutional principles in place to rule taxation, which creates the need to fight the above mentioned rules.

Among the services we offer to prevent the application of tax laws that are unconstitutional or illegal, are:

-The Filing in of Amparo against laws or regulations of a fiscal nature.

-The Filing in of the action for judicial review against rules, agreements and other regulations in which tax norms are contained.

In order to face the tax control acts carried out by the tax authorities, tax payers must have the appropriate advice so as to correctly integrate the evidence and arguments which can invalidate the acts or omissions alleged by the authority. This has the purpose of eliminating or minimizing adverse consequences.

Among the services of representation before the authorities we offer, are:

-Counselling during on-site regulatory audits, desk reviews and report reviews or electronic reviews.

-Counselling in order to sign conclusive or self-correction agreements.

-Developing and processing of queries.

-Counselling during the tax refund process.

-Developing and processing of the condonation of taxes and related charges proceeding.

-Counselling during the Co-operative Compliance proceeding.

-Joint appearance before tax authorities.

The daily operations of business activities are subject to review by the tax authorities, who may interpret differently the meaning of the operations carried out by the taxpayer and then modify their fiscal effects.

Therefore transactions having economic consequences or/and fiscal relevance should go through analysis and should be backed up with opinions giving them legal support. In these cases we offer opinion based on:

-The Interpretation of tax laws related to civil, commercial and administrative law.

-The Criteria issued by specialized courts.

-The Criteria published by tax authorities.

-Several Sources of international law.

In Castellanos Abogados Fiscalistas, S.C., we evaluate our clients’ tax contingencies to offer them alternatives generating solutions instead of risk, according to the best practices of tax compliance and always in the sake of the company performance.