Advisory & planning

The cheapest indirect tax dispute is the one that never starts. A position taken correctly at the outset — and documented at the time — usually costs a fraction of defending the same position five years later against a department that has had time to build its file.

What this covers

• Written opinions on specific transactions and positions
• Classification and HSN or SAC determination
• Place of supply and cross-border questions
• Valuation, including related-party and corporate guarantee questions
• Input tax credit eligibility, blocked credits and reversal exposure
• Reverse charge applicability
• Indirect tax due diligence and health checks
• Second opinions on positions already taken

Why clients bring us this work

Our advisors’ opinions are regularly sought by Chartered Accountants, CFOs and senior management, and have in several instances been accepted at the policy-making level in Government and contributed to corrections in the indirect tax framework.

Common questions

We already have a Chartered Accountant. What does a separate opinion add?

A good deal of our advisory work comes to us through Chartered Accountants rather than around them. The value we add is on the litigation-facing question — how a position will be attacked, what the department has argued before, and what record needs to exist now for it to be defensible later.

Is a written opinion useful if a dispute arises anyway?

It frequently is. A reasoned opinion obtained before a position was taken is contemporaneous evidence of bona fides, which is directly relevant where the department alleges suppression or wilful misstatement to invoke the extended period.