Tax controversy

Unfortunately, issues and disagreements with tax authorities do arise. This is particularly an issue in a region where tax laws and regulations may be unclear or do not seem to anticipate all the different ways business or investment may be conducted. Furthermore the availability and efficiency of dispute settlement mechanisms varies greatly.

As the Middle East & Africa (MEA) region rapidly develops, as with any emerging or frontier markets, and succeeds in attracting Foreign Direct Investment, various factors can delay much needed legislation, or infrastructure, in order to facilitate the sophisticated transactions and arrangements that are being negotiated.

In much of the region, foreign investors often look for greater protection than current laws and regulation seem to permit, such as greater transparency and certainty over potential tax liabilities. Cragus tax professionals have significant experience in properly and professionally determining tax liabilities with relevant tax authorities, and very often we advise on the application of tax legislation and treaties, and also on reciprocal arrangements, where laws and regulations are ambiguous.

Unfortunately, issues and disagreements with tax authorities do arise. Even when a client has taken great care in being tax efficient without taking unacceptable risk, there may be a disagreement with the tax bureau or inspectors on the interpretation of the law or how a particular transaction should be characterized. This can be a particular problem in the region where tax laws and regulations may be unclear or do not seem to anticipate all the different ways business or investment may be conducted. Furthermore the availability and efficiency of dispute settlement mechanisms varies greatly. With our network of members and correspondent firms, who in most instances are prominent local law firms, we are uniquely placed to help our clients resolve tax issues and disagreements, usually through negotiation and direct settlement.