Tax dispute resolution

Tax disputes are rising globally as governments focus on perceived underpayment. Cross-border taxation issues such as transfer payments, in particular, are creating a surge of disputes because new legislation creates grey areas and the need for test cases. This makes tax disputes a fact of life for firms with complex tax positions.  

Our approach  

Businesses are facing an environment where audits from tax authorities are on the rise. As tax laws become more stringent and regulations more complex, companies have an incentive to avoid disputes whenever possible. We aim to prevent tax disputes at source with robust, risk-based tax advice. We can also advise on record keeping and other processes to minimise the chances of proceedings. 

When disputes occur, however, we offer consistent assistance throughout a difficult process which can take, in some cases, many years.  We also provide strategic guidance on the risks and benefits of arbitration versus court proceedings and whether to accept settlement offers. We also advise on criminal action being taken against both companies and individuals. 

Our dedicated local tax dispute teams in major jurisdictions have detailed procedural and administrative knowledge that can make an important difference to outcomes, with the ability to draw on global expertise in areas such as transfer pricing and customs duties. 

We can also advise on issues such as alleged non-payment of minimum wages and executive remuneration that have a labour law component. 

Our services  

We offer support, covering the following:

• Analysis of existing risks to minimise the possibility of tax litigation.
• Formulation of queries before the Directorate General for Taxation.
• Advice on administrative requirements, administrative checks and tax inspections.
• Advice on obtaining deferrals and instalments of tax debts.
• Appeals and tax claims. Advice on obtaining suspensions.
• Experience in transnational mechanisms such as the Friendly Procedures provided for in Double Taxation Conventions and binding arbitration within the framework of the OECD.

Our people   

Our teams include, in some cases, staff who have worked with local taxation authorities who can provide a unique perspective.