Burden of Proof

The burden of proof is a foundational principle in legal proceedings, requiring a party to demonstrate the truth of their assertions to the requisite standard of evidence. In tax law, the burden of proof often determines which party—typically the taxpayer or the revenue authority—must establish that a transaction, deduction, or tax position is justified. This principle ensures fairness and clarity in adjudication, setting a clear pathway for presenting evidence and arguments.

In tax disputes, the burden of proof may vary based on jurisdiction, the nature of the case, and applicable statutory provisions. For example, in some jurisdictions, the initial burden lies with the taxpayer to prove compliance with tax laws. However, if the tax authority challenges the taxpayer’s position, the burden may shift, requiring the authority to provide evidence of non-compliance or tax evasion. Standards such as “balance of probabilities” in civil cases or “beyond a reasonable doubt” in criminal cases further refine how the burden of proof is applied.


Examples of Burden of Proof in Practice

Example 1: Transfer Pricing Disputes

In a transfer pricing dispute, a taxpayer might claim that intercompany transactions comply with the arm’s length principle. The burden of proof often lies with the taxpayer to provide documentation, such as transfer pricing reports, comparability analyses, and agreements, to substantiate this claim. If the tax authority challenges these transactions, the burden may shift, requiring the authority to provide evidence demonstrating why the taxpayer’s methodology does not reflect arm’s length pricing.


Example 2: Claiming Deductions

A company claiming a significant business expense deduction must bear the burden of proof to show that the expense is legitimate, incurred wholly and exclusively for business purposes, and adequately documented. If audited, failure to provide sufficient evidence, such as invoices and receipts, could result in disallowance of the deduction and additional penalties.


Example 3: Alleged Tax Evasion

In criminal tax cases, where the revenue authority accuses a taxpayer of evasion, the burden of proof shifts significantly. The authority must prove beyond a reasonable doubt that the taxpayer intentionally evaded taxes. This often involves presenting compelling evidence, such as falsified records or hidden assets, to meet the higher evidentiary standard.


Cases Featuring the Burden of Proof

Helvering v. Gregory

This landmark US tax case addressed whether a transaction lacked economic substance. The burden of proof lay with the taxpayer to show that the transaction was not solely tax-motivated but had a legitimate business purpose. The case set significant precedents for assessing the economic substance doctrine.


Danville Plywood Corporation v. United States

In this case, the taxpayer was required to prove that inventory valuation methods adhered to statutory requirements. The court ruled against the taxpayer due to insufficient evidence, underscoring the importance of meeting the burden of proof in substantiating tax positions.


X Holding BV v. Staatssecretaris van Financiën

This EU case highlighted how the burden of proof operates in determining whether an arrangement is genuine or abusive under the EU freedom of establishment principle. The taxpayer had to demonstrate that its arrangement was not wholly artificial and met the requirements of EU law.