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Tax controversy and dispute resolution

Taxpayers are facing the most challenging tax environment in history – this requires a full spectrum of disciplines to enable proactive and strategic approaches to tax audit and dispute prevention, management, and resolution.

The driving themes in today’s global tax landscape include enhanced tax transparency, tax efficiency, and improved tax dispute resolution mechanisms, driven in part by the OECD’s base erosion and profit shifting initiatives. In this global tax environment, taxpayers are faced with a number of new challenges that are in turn creating increased uncertainty.

The source of these challenges is primarily attributable to enhanced enforcement actions by tax administrations to increase revenues and address budget gaps. These actions are focused on engaging in aggressive audit and examination tactics, implementing unilateral measures that diverge from international standards, promulgating transparent reporting requirements, and developing robust risk assessment tools. As a result, there has been a substantial increase in the number and size of tax audits and disputes worldwide, placing further strain on the resolution of treaty-related disputes and increasing the risk of double taxation.

Greater risk and uncertainty causes taxpayers to re-evaluate their approach to proactively prepare for and resolve tax audits and disputes. This necessarily requires a multidisciplinary approach that utilizes tax and legal service providers with a global reach that are highly credentialed and well equipped to appropriately assist taxpayers in all phases of the tax dispute and controversy lifecycle.

ILC Legal, LLP, as an independent law firm in the PwC network, can assist taxpayers with their tax controversy and dispute resolution needs by providing access to a full spectrum of seasoned professionals across the PwC network of firms, inclusive of law firms within the PwC global legal services network, covering tax controversy matters in more than 90 countries.

The tax controversy and dispute resolution service offering can help you proactively and strategically prepare for and resolve your tax audits and disputes that arise around the globe – from pre-audit steps to tax litigation

Working with other PwC network firms, ILC Legal, LLP can deliver services tailored to your needs

The tax controversy and dispute resolution service offering

Audit and dispute prevention techniques

  • Build ‘defense strategies’ into business structures and operations
  • Engage with tax authorities upfront to gain certainty, such as entering into pre-filing agreements and advance pricing agreements (APAs)
  • Perform ‘health check’ analyses and identify potential risk areas as early as possible
  • Conduct ‘mock audits’ of specific issues and structures
  • Coordinate ‘course of conduct’ reviews to ensure that post-structuring operations align with initial implementation plans
  • Develop master impact statements, including quantitative and qualitative impact of positions
  • Prepare transfer pricing documentation and standard operating procedures for transactions 
  • Prepare thorough “defense files” in anticipation of audits or disputes of transactions or operations
  • Assist with proper documentation of major transactions
  • Coordinate document identification, collection, and centralization procedures

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Strategic planning of tax audits and disputes

  • Develop specific, consistent strategies for:
    • Key countries and larger areas of concern
    • Issues that apply to multiple jurisdictions
    • Utilization of credits and other tax attributes
    • Global documentation policies
  • Create global database of procedural requirements, critical issues, active tax authority proceedings, APAs, issue resolutions, competent authority negotiations, and arbitration proceedings

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Audit management practices

  • Identify leading practices involving all phases of audits:
    • Coordinate responses to information document requests
    • Develop issue defense strategies and position papers
    • Prepare for employee interviews, depositions, and facility tours
    • Plan for and engage in tax administration discussions
  • Identify early referrals to appeals or competent authority program
  • Assist with filing of refund claims

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Dispute resolution alternatives

  • Identify and assist with dispute resolution alternatives, such as:
    • APA processes
    • Administrative appeals
    • Simultaneous appeals and competent authority proceedings
    • Post-appeals non-binding mediation
    • Competent authority proceedings
    • Mandatory binding arbitration
  • Where appropriate, perform litigation support and conduct litigation (in some countries)

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PwC's global legal services network of firms has the largest geographical reach with unparalleled access to experienced legal professionals around the world, making it a leader in the marketplace. However, it is the network’s approach and the value you will realize that makes PwC’s approach different and distinctive.

Global reach

With tax and legal professionals located in over 90 territories, the PwC global legal services network of firms has the requisite footprint to deliver local expertise in jurisdictions around the world, providing the appropriate multi-jurisdictional services you need to track global trends and support growth agendas as well as seamlessly prevent, manage, and resolve audits and disputes worldwide.

Proven track record

The track record of the PwC’s tax controversy and dispute resolution service offering runs deep – with years of experience helping clients proactively prevent, efficiently manage, and favorably resolve tax controversies throughout the world in all areas of both direct and indirect tax.

Local insights

PwC’s network of firms that provide the tax controversy and dispute resolution service offering include many former high-ranking government tax officials who have key relationships with local revenue authorities along with a thorough understanding of local dispute processes and procedures. These abilities, in turn, help to manage and resolve tax audits and disputes in a more effective and efficient manner.

Multi-disciplinary approach

Tax controversy and dispute resolution services necessarily require advice from a number of different disciplines to enable a holistic approach. PwC’s network of firms can seamlessly deliver these various disciplines through access to forensic scientists, valuation and accounting specialists, economists, and legal professionals.

Proactive, not reactive

A close examination of trends in the global tax environment may better equip taxpayers to proactively and strategically plan for tax audits and disputes. PwC’s tax controversy and dispute resolution service offering can help you build strong defense strategies, including early communications and negotiations with tax authorities before an audit occurs, to provide upfront certainty and reduce risk.

Role of technology

PwC’s tax controversy and dispute resolution service offering relies on innovative technology tools and processes to help automate the management of global tax audits and disputes, enabling you to achieve cost savings and create efficiencies.

Contact us

Richard Edmundson

Managing Partner, ILC Legal, LLP, PwC ILC Legal

Tel: +1 (202) 313 8502