The New Era of Taxation
10 Sep - 12 Sep 2025
Session information
Tax controversy – burden of proof in litigation and mediation with tax authorities
Friday 12 September (0900 - 1030)
Description
The burden of proof plays a pivotal role in both tax litigation and alternative dispute resolution with tax authorities. This panel will analyse how different jurisdictions allocate the burden between taxpayers and tax administrations, and how this impacts the outcome of disputes. Particular attention will be given to evidentiary standards, the role of presumptions, and practical strategies for meeting documentation requirements in complex cross-border cases. The panel will also address how burden of proof considerations influence the dynamics of tax mediation and settlement procedures.
Speakers
| Alex Cordova | Rodrigo Elias & Medrano Abogados, Lima, Peru |
| Wojciech Marszalkowski | Wardynski & Partners, Warsaw, Poland |
| Jenni Parviainen | Hannes Snellman, Helsinki, Finland; Membership Officer - Europe, Taxes Committee |