Tax controversy and dispute resolution: Overview

Multinational corporations (MNCs) are facing the most challenging tax environment in history: a convergence of global forces has resulted in a substantial increase in the number and size of tax audits, assessments, and disputes with revenue authorities worldwide.

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Fiscal demands on developed and emerging countries have placed considerable pressure on governments to raise revenue and prevent the erosion of their tax bases. Governments worldwide are cooperating as never before to share taxpayer and industry information, assist other countries with document and information requests, and participate in separate multi-country audits (including “simultaneous” examinations). Some countries are even considering the concept of "joint audits" where a single audit team--comprised of government tax inspectors and auditors from two or more countries--examines a specific taxpayer. At the same time, MNCs are experiencing increasingly complex regulations, heavy penalties, and transparency and disclosure issues.

These global forces have created an unprecedented surge in audits and disputes. Virtually no area of tax enforcement has escaped this phenomenon, which includes direct taxes (domestic and international) and indirect taxes (e.g., VAT and GST), as well as specialist areas such as customs, tax fraud, and white collar tax issues. This new situation places a premium on audit and dispute prevention techniques because MNCs are under constant competitive pressure to structure their worldwide business operations effectively and efficiently. MNCs need to develop coordinated approaches to audits and disputes around the globe, adopt preventative measures (such as pre-filing rulings and enhanced relationships with certain revenue authorities), and leverage both traditional and new alternative dispute resolution techniques in order to achieve the best possible results.

PwC’s Tax Controversy and Dispute Resolution network assists taxpayers in this emerging area. We can work with you to prevent, efficiently manage, and favourably resolve tax audits and disputes throughout the world. PwC has tax specialists to assist clients in virtually every area of dispute. We combine deep technical understanding, local knowledge, strong relationships with government officials, tax litigation experience, and a global perspective to provide you with unrivalled service.