Overview

Tax authorities worldwide are under pressure to generate revenue, causing a rise in tax audit activity across all types of tax. Particular uncertainty can arise as businesses seek to access new and developing markets where the local tax environments may be unfamiliar and unpredictable.

The pressure on tax authorities is resulting in more investigations, larger adjustments and increased potential for penalties and interest. Wherever companies do business, they need to approach tax matters proactively and be ready to respond when a tax investigation begins. In addition, as revenue authorities seek to achieve their local goals, collaboration with other revenue authorities has become more visible and focused, leading to additional challenges in managing disputes across a number of jurisdictions.

How clients benefit

Our Tax Dispute Resolution & Controversy Services teams help clients mitigate against risks and manage/ resolve issues so they can gain control over the uncertainty inherent in tax disputes within their operational jurisdictions and across borders.

Our specialists, including many former revenue authority officials, accountants and attorneys, are experienced in all stages of the tax dispute continuum. Our approach is designed to help organizations address tax disputes through effective strategies for their mitigation, management and prompt resolution. 

 

Our Approach

1. Protect - Transaction and documentation  review  tax  reporting 

-Evaluating transactions ‘from the revenue authority’s perspective’ and providing assistance in working through the relevant processes to obtain technical rulings, opinions, and case laws in advance of your transactions.

-Preparing documentation and files to support tax positions in anticipation of future tax authority requests for information.

-Navigating voluntary disclosure, advance compliance and other tax authority programs.

 

2.  Manage - Tax audits and queries

-Responding to tax authority demands for information or documentation.

-Negotiating audits, responses to audit queries and, where regulations permit, judicial appeals.

-Engaging with the tax authority to agree on a project-based approach to progressing issues collaboratively.

-Working with senior officials to help ensure stated administrative policies and procedures are followed.

 

3.  Resolve - Tax dispute and controversy process

-Making informed decisions on preferred options for resolving difficult disputes (e.g. alternative forms of dispute resolution and/or litigation).

-Finalizing settlements and ensuring appropriate documentation is maintained.

-Managing the tax dispute resolution process in a nonconfrontational and effective manner.

-Using all available procedures and processes to help bring closure to your disputes, effectively and efficiently.