Dispute Resolution
When your position is challenged, our job is to help you defend it - clearly, confidently, and effectively.
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At CAVOK Advisory, we support you through the entire tax controversy lifecycle - whether you're preparing for a potential audit, managing an ongoing dispute, or seeking long-term certainty through APAs. Our approach is practical and senior-led, combining technical depth with hands-on support, clear communication, and an understanding of your commercial priorities.
We work alongside your team and local advisors to ensure your transfer pricing story is not only defensible, but coherent, well-documented, and aligned with both OECD guidance and local law.
Pre-Audit Readiness
We assess your current position and documentation to identify likely audit risks, reviewing contracts, intercompany communications, and existing documentation. We help you strengthen your documentation to improve audit resilience and align fully with OECD and local requirements.
National Tax Tribunal
Should your audit settle unfavorably, we help prepare your case before the NTT, managing submissions, discussions with the case handler, and helping you present a clear, technically sound position before the tribunal.
Disclosure
If historical gaps have been identified, we guide you through voluntary disclosure and remediation strategies. This includes assessing exposures, preparing documentation, managing authority interactions, and advising on potential penalties and mitigation steps.
Post-Audit Support
We help you mitigate double taxation resulting from audit adjustments, including pursuing Mutual Agreement Procedures (MAP) or arbitration - always with a focus on achieving an acceptable outcome for you.
Audit Support
We support you throughout the audit process - from preparing responses and supplementary documentation to discussions with tax authorities, helping you navigate the audit with confidence.
Future Certainty (APA)
We assist in securing long-term transfer pricing certainty through Advance Pricing Agreements (APAs), including strategic planning, preparation of documentation, liaison with tax authorities, and negotiation support. APAs can help “lock in” your pricing approach for several years, reducing future risk and administrative burden.