Contentious tax proceedings demand procedural precision, sound commercial judgement and the willingness to argue a position through every instance.
PACTUM represents entrepreneurs, shareholders and companies in contentious tax proceedings — from objection proceedings against the tax authorities through actions before the fiscal courts to appeals to the Federal Fiscal Court. The focus is on proceedings where real value is at stake and careful preparation makes the difference.
What we argue, we have fully mastered. What we challenge, we challenge consistently. A tax dispute is not won at the oral hearing — it is won in preparation, starting with the first look at the assessment notice.
Representation in extrajudicial remedy proceedings against the tax authorities — from filing within the deadline through a substantiated statement of grounds to the objection decision.
Interim relief against immediate enforcement of contested assessments — applications for suspension of enforcement before the tax office and fiscal court, including questions of security.
Conducting fiscal court proceedings — statement of claim, presentation of facts, offers of evidence and oral hearing, including expedited and inaction actions.
Representation at the appellate level — complaint against non-admission, statement of grounds for appeal and hearing before the Federal Fiscal Court in Munich, including hearing complaints.
Supporting tax field audits with the later dispute in view — closing meeting, factual settlement and strategic positioning before the assessment is issued.
Structuring advice before conflict arises: binding rulings, applications for equitable relief, and correcting assessments outside formal remedy proceedings.
We analyse the assessment notice and audit report, secure the deadlines and give an honest assessment of the prospects of success — without detours and without unsolicited reservations.
Filing the objection within the deadline and providing substantiated grounds — in parallel, on application, we secure suspension of enforcement so the disputed tax need not be paid upfront.
If the objection is unsuccessful, we conduct the court proceedings — with complete presentation of the facts, precise offers of evidence and thorough preparation of the oral hearing.
Where the matter is of fundamental significance or departs from supreme court case law, we take the case to Munich — via complaint against non-admission or an admitted appeal.
Enforcing the outcome through to the amended assessment — including refund, interest and costs determination. A won case is not concluded until it is implemented.
Objection, action and appeal proceedings before the tax authorities, fiscal courts and the Federal Fiscal Court.
Cumulative amount in dispute across tax proceedings conducted over the past five years, in EUR.
Every case is personally led by Christoph Bubb — from the initial assessment to the decision.
Talk to us early — the objection deadline is generally one month. A well-run tax dispute begins before the deadline expires, not after.
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