Tax Controversy

Confidently manage tax controversy with tax authorities globally

Tax controversies typically are unique, urgent, and inconvenient. Without proper guidance and coordination, multinational organizations can spend enormous amounts of time and resources addressing tax disputes across jurisdictions. In today’s tax landscape, where authorities investigate technical merit and analysis as well as implementation and motive, you need experienced, knowledgeable specialists to provide a detailed and customized solution.

Through decades of working on a broad range of tax issues, we have fine-tuned our technology, analytic procedures, and response methodologies to offer a broad-based, scalable solution that we can tailor to each client and tax controversy.

Deloitte's tax controversy teams include individuals with a range of skills and experience, including former tax administration employees, alternative dispute resolution professionals, and, in many countries, tax litigation specialists, all supporting you throughout the tax dispute resolution cycle. We work across all tax fields, including domestic income tax, international tax, transfer pricing, indirect tax, and specialty areas such as incentives; in some markets, we also provide tribunal and court representation. Services include audit readiness assessment and preparation; strategies to minimize the impact of tax controversies; support for mitigation of potential disputes through revenue authority ruling systems; support for international treaty procedures; application of advanced pricing agreements (APAs), and other such tools.

• Planning and preparation to minimize disputes
• Documenting and preparing evidence and defense files
• Reviewing and finalizing global strategic controversy-aware policies
• Bilateral and multilateral advanced pricing agreements (APAs)
• Advanced rulings and unilateral APAs
• Pre-transaction engagement with tax authorities
• Ongoing proactive engagement with tax authorities
• Obtaining and negotiating tax authority rulings

• Tax authority inquiry handling and closure
• Global inquiry process tracking
• Negotiation with tax authorities
• Analysis, economic and technical support
• Appeal and litigation support
• Mutual agreement procedure (MAP) and arbitration support
• Evidence preparation including witness interviews and discovery
• Mediation and alternative dispute resolution techniques
• Litigation representation (in certain countries)