Tax Disputes & Appeals

Tax assessments and penalties issued after an inspection are not final. They can be challenged — but only within short statutory deadlines and on properly documented grounds. Many businesses lose the right to object simply by letting the period lapse while negotiating informally.

Wise Counsel advises Vietnamese and foreign-invested companies through tax inspections, and represents them in administrative complaints and court proceedings against tax assessments, penalties and refund refusals.

What we help with

• Advising during tax inspections and audits, including how to respond to information requests
• Reviewing draft inspection minutes before signing and advising on reservations to record
• Assessing the legal basis of assessments, penalties and late payment interest
• Preparing and filing administrative complaints with the tax authorities
• Representing clients in administrative litigation against tax decisions
• Disputes over transfer pricing adjustments and related-party transactions
• Disputes over VAT refunds, invoice validity and deductible expenses
• Advising on treaty relief and double taxation issues
• Advising on voluntary disclosure and penalty mitigation where errors are found

The most valuable work in a tax dispute usually happens before the decision is issued. We advise clients to involve us at the inspection stage, not after the assessment arrives.