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.