Our approach

      Whether triggered by policy shifts, audits or enforcement activities, tax disputes are no longer exceptions, they’re an operational reality.

      As cross-border complexities deepen against a backdrop of heightened regulatory scrutiny, managing tax risk means more than defending a position. It means anticipating challenges, preventing escalation and resolving issues proactively and strategically, both within jurisdictions and across borders.

      From audit readiness and early engagement with tax authorities to navigating complex negotiations, litigations and mutual agreement procedures, our Global Tax Dispute Resolution & Controversy Services teams do just that: providing an approach to handling controversy that is designed to keep you in control before, during and after a dispute.

      Combining well-established tax authority relationships with intelligent technology and a globally coordinated network, KPMG professionals work to help you mitigate exposure, maintain reputation and protect long-term value throughout the tax dispute continuum.

      Whether you’re facing transfer pricing inquiries, cross-border audits or multijurisdictional litigation, we’re here to respond with the urgency, strategy and diplomacy your tax controversy demands.


      What we deliver

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      Comprehensive tax controversy

      From early risk identification to post-audit resolution, we support the lifecycle of tax controversy — helping you respond and resolve with controlled precision.

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      Strategic tax authority engagement

      With deep experience and long-standing tax authority relationships across multiple jurisdictions, we can navigate complex controversy interactions with credibility and confidence.

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      Complex cross-border coordination

      Spanning jurisdictions and tax domains, our global network and specialist local experience combine to coordinate complex defense strategies and consistent positions for robust protection, worldwide.


      Our services

      Empowering your tax dispute resolution strategy. Discover how our approach helps you stay in control before, during and after a controversy.

      Strategic counseling

      Effective tax dispute resolution should go beyond litigation. The broader implications of a controversy and your approach to tax risk management can significantly impact your organization. Leveraging KPMG professionals deep understanding of common audit focus areas and tax authority policies, we can help you proactively reduce risk and enhance your readiness for tax audits.

      Tax dispute handling

      Navigating a tax dispute requires a tailored strategy. Our experienced teams evaluate the unique aspects of your case, considering both local and international factors, to recommend the most effective approach for resolution.

      Tax dispute preparation: Data-gathering and sorting

      Success in tax courts depends on robust evidence. We assist in gathering, organizing, and selecting the critical documentation needed to strengthen your position and achieve the best possible outcome in any tax dispute.

      Tax dispute management: Workflow management

      Managing multiple tax disputes across jurisdictions can be complex and demanding. Our specialists provide guidance on streamlining your processes, utilizing advanced tools to efficiently oversee and resolve disputes worldwide.

      Tax dispute prevention: APA

      Advance Pricing Agreements (APAs) can proactively prevent disputes before they arise. Our experienced professionals support you through the APA process, helping you gain certainty and reduce risk.


      Our insights

      Explore the current trends and dispute developments shaping today’s tax landscape, with in-depth perspectives from over 115 KPMG tax dispute professionals across 49 jurisdictions across the world.

      KPMG TaxNewsFlash reports on tax controversy and dispute resolution developments from around the globe.

      Discover the strategic imperatives and actionable insights helping today’s tax professionals navigate the forces of change in tax policy, AI and talent.

      Navigate the future of tax with pressing business issues and opportunities facing today’s strategic tax leaders and the asset management landscape.


      Explore more with KPMG Tax Dispute Resolution & Controversy Services

      Discover how KPMG tax professionals can help you navigate global tax complexities to transform tax into a strategic advantage.

      Discover how KPMG Law professionals provide General Counsel and Heads of Legal with holistic approaches that integrate legal advice with other business and financial services.

      Explore how we bring deep tax experience, industry focus and advanced technology to support your tax strategies from our regional centers around the world.


      Our people

      Aldo Mariani

      Head of Global Tax Dispute Resolution & Controversy Services

      KPMG International