Tax controversy and dispute resolution

Multinational corporations 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. 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 multinational companies (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.

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Find out more about the top issues multinational companies are facing today including in-depth articles on the latest developments on tax controversy, the step by step audit process by country and much more.

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Tax controversy life cycle

Pre-audit prevention phase

  • building "defence strategies" into the structure and operations of an enterprise;
  • negotiating pre-filing rulings, including unilateral agreements, Advance Pricing Agreements, and accelerated Competent Authority / Mutual Agreement Procedure negotiations;
  • pro-actively negotiating with the tax authorities at the pre-audit stage to gain earlier certainty and achieve penalty protection;
  • coordinating "course of conduct" reviews to ensure that post-structuring operations align with initial implementation plans;
  • assisting in transactional due-diligence to identify tax audit and controversy risks and exposures; and
  • once risks are identified, develop and implement other option to the current business model to mitigate your company's risk profile.

Audit / examination phase

We can help you in managing and responding to investigations, audits, and examinations initiated by revenue authorities worldwide. This includes routine and complex audit management related to information requests, large document production, informal and formal interviews and depositions of company personnel, and orchestrating plant and facility tours. In addition, we assist in audit level presentations, negotiations, and settlement discussions in order to resolve disputes efficiently and favourably.

Post-audit settlement / resolution phase

If your tax dispute is not resolved, we can provide you with a full range of dispute resolution options.

How PwC can help you

Our Tax Controversy and Dispute Resolution network can help you gain a better understanding of your company’s risks and exposures--and manage your tax disputes, audits, and examinations worldwide. We can help you to implement consistent and defensible practices and policies.

Our Tax Controversy and Dispute Resolution services are delivered in five key areas:

  • Tax dispute prevention techniques
    We can help you develop sound policies and processes that can provide defensible models and help safeguard your organisation against audits and disputes.
  • Tax audit management practices 
    By understanding your organisation and its policies, we can help you effectively manage tax audits and examinations.
  • Tax dispute resolution alternatives
    We can work with you, at both the local and international level, to implement practices that can reduce or eliminate prolonged disputes--or the likelihood of costly litigation, and leverage our expertise in virtually all forms of tax dispute resolution.
  • Global strategic planning of tax audits and disputes
    We can help you develop global tax dispute resolution strategies that are consistent with your goals, and utilise a wide variety of key tax approaches. We can also help you develop strategies for establishing consistent tax positions and methods worldwide, and across a variety of tax technical areas.
  • Tax risk management, analysis and disclosure
    We can analyse your various tax positions that may require financial statement disclosures, and help you develop sound policies and practices, including appropriate documentation and disclosure approaches. These proactive practices should provide a defensible approach and rationale, to safeguard your organisation against non-compliance penalties and other exposures.

Why PwC?

Our Tax Controversy and Dispute Resolution network includes accountants, economists, and industry sector specialists, all of whom possess in-depth knowledge and experience of individual sectors. Our aim is to help you prevent, efficiently manage, and favourably resolve tax audits and disputes.

Local knowledge and strong relationships with government officials

The successful management and resolution of audits and controversies relies heavily on having strong relationships with revenue authorities, and a thorough understanding of local processes and procedures. Our network includes individuals who are members of local specialist groups, as well as former high-ranking government tax officials who have substantial experience working on audits and disputes, both from a client and revenue-authority perspective.

Global reach and perspective

Our Tax Controversy and Dispute Resolution professionals are located in territories which are regarded as aggressive tax enforcement jurisdictions, or are considered to be of key strategic importance from a tax perspective. This means we can provide you with the appropriate support to help you resolve your tax audit or dispute, wherever you need it. We can offer this support on a unilateral, bilateral, or multilateral basis, depending on your needs.

Deep technical subject matter expertise

Revenue authorities are now engaged in enforcement activities across the entire tax spectrum, including direct and indirect tax, as well as other related areas. As a result, organisations should ensure that they have the support of technical specialists in the tax area in which the audit or dispute is focused. 


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Contact us

David Swenson

Global Tax Controversy and Dispute Resolution Leader, PwC Global

Tel: +1 (202) 414 4650

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