We assisted a very wealthy private individual in a large-scale tax dispute that concerned expatriation.
The tax authorities reviewed the taxation of the private individual through a subsequent assessment, arguing that the final preliminary ruling on the individual’s expatriation could be disregarded as subsequent assessment showed that some of the future plans included in the application had not been realised. The reassessment of taxation carried out by the Tax Administration led to significant residual taxes for the individual. A key issue in the tax dispute was whether genuine expatriation could be subject to the tax avoidance regime.
