As in any tax proceeding, the burden of proof is shared. The tax authority must prove the facts that increase the tax liability. The taxpayer, for their part, must prove the facts that reduce or eliminate it, such as the non-taxable source of funds (inheritance, gift).
Who bears the burden of proof in a tax reassessment proceeding?
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About the Author: Attorney Cedric PANCHAUD
Cédric Panchaud is an attorney, holds a doctorate in law, is a licensed notary, and is a certified tax expert. He heads PANCHAUD Tax & Legal SA, an independent firm in Geneva specializing in taxation of individuals and corporations, real estate taxation, occupational pension plans, and corporate restructuring. He regularly serves as a speaker at continuing education seminars (ISIS, OREF/EXPERTsuisse).