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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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:

We can help you develop sound policies and processes that can provide defensible models and help safeguard your organisation against audits and disputes.

By understanding your organisation and its policies, we can help you effectively manage tax audits and examinations.

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.

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.

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.

Tax controversy life cycle

Taking proactive steps before an audit or dispute begins

Responding to audits and managing the overall process

Providing strategic solutions to resolve disputes

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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. 

Check out our Tax Controversy Mobile Solution

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.

For Android devices, download PwC's Tax Controversy from Google Play

For IOS devices access the web app and once you’ve loaded the website, click on the “Share” icon next to the URL in the second row of icons, scroll to the right until you locate “Add to Home Screen”.

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Contact us

Giovanni Bracco

Global Tax Controversy and Dispute Resolution Co-Leader, PwC United Kingdom

Tel: +44 7764 235336

Hayden Scott

Global Tax Controversy and Dispute Resolution Co-Leader, PwC Australia

Tel: + 61 7 3257 8678