Services

Tax controversy

When a tax dispute (audit level, administrative appeals, MAP, court litigation) is material to the client and controversy services become necessary, Deloitte’s proactive insights can help provide a foundation on which to build and implement forward-thinking tax controversy resolution strategies.

The tax controversy challenge

Global tax & legal controversy services Global trends (BEPS, ICAP using CbC-Reports, joint audits, etc) accelerate the exchange of information about multinational organizations. Data leaks disclose corporate tax-planning structures (Lux leaks, EU state aid, Malta Files, Paradise Papers, etc). International tax disputes will increase.

Why it matters

As a result, multinational organizations face increasing pressures to manage international tax disputes in both headquarter and foreign jurisdictions.

The teams within multinational organizations are not staffed or calibrated to deal with international tax disputes. They are not aware of pending disputes across their organization. They are not trained to manage disputes across jurisdictions. They are not aware of proactive strategies to prevent costly and
time-consuming disputes.

What Deloitte does about it

A multidisciplinary problem requires a multidisciplinary solution. In direct response to our clients’ rising need for controversy services, professionals from across Deloitte collaborate to centralize our firm’s legal, business, tax, and compliance knowledge.

Pooling our insights from a host of disciplines and jurisdictions around the world enables Deloitte to provide businesses with a cohesive perspective and empower them to make informed business decisions at any stage of the tax controversy cycle.

When a tax dispute (audit level, administrative appeals, MAP, court litigation) is material to the client and controversy services become necessary, Deloitte’s
proactive insights can help provide a foundation on which to build and implement forward-thinking tax controversy resolution strategies.

End-to-end controversy services

Prevent

  • Data readiness
  • Contemporaneous evidence documentation
  • APA
  • Binding rulings
  • Risk profiling
  • Mock audits and raids
  • Voluntary disclosures exempting from fines and punishment

Manage

  • Agency investigation powers and corporate cooperation
  • Audit negotiation and settlement
  • Legal protection against audit actions
  • Voluntary disclosures exempting from fines and punishment

Settle / Litigate

  • Competent Authority, MAP
  • Evaluation on prospects of success of court litigation
  • Administrative appeals
  • Court litigation
  • Interim legal protection

Defend

  • Criminal investigations
  • Criminal court litigation

* permissibility is subject to local rules and practices.

Tax Controversy Newsletter for Inbound

The Deloitte Tohmatsu Accountant Tax Accountant corporation experts will explain the trends and countermeasures of recent tax cases based on advanced expertise and abundant achievements in an easy-to-understand manner.

>> Click [Tax Controversy Newsletter for Inbound] for more details

The Latest Articles

Listed are latest articles written by the Deloitte tax controversy experts.

>> Click [The Latest Articles] for more details

Professionals

Hiroki Yamakawa

Hiroki Yamakawa

Deloitte Tohmatsu Tax Co. Partner

During his over 30-year service at the NTA, Mr. Yamakawa assumed key positions such as Director of the Office of Mutual Agreement Procedures and Director of the Large Enterprise Examination and Crimin... More

Yutaka Kitamura

Yutaka Kitamura

Deloitte Tohmatsu Tax Co. Director

Attorney at Law admitted in Japan and the State of New York, and Certified Public Tax Accountant. He joined Nagashima Ohno & Tsunematsu (2000~2009), Financial Tax Office, Policy and Legal Division, Pl... More