Tax controversy solutions

Multinational organizations continue to spend time and resources managing tax controversies and disputes in both headquarter and foreign jurisdictions. Tax authorities are sharing information about companies and focusing increasingly on implementation failure and motive, not just pure tax technical merit or analysis.

Lawyers from Deloitte Legal routinely work closely with other Deloitte tax professionals. It is this combination of legal, business, tax, and compliance knowledge that enables Deloitte to provide businesses with a cohesive perspective, enabling companies to make informed business decisions at any stage of the tax controversy cycle. Deloitte Legal’s proactive insights can help provide a foundation on which to build and implement forward thinking tax controversy resolution strategies.

Deloitte Legal’s tax controversy and dispute resolution practices include former tax authority officials and alternative dispute resolution specialists to help multinational companies consistently control and manage tax controversies across multiple jurisdictions. This approach streamlines and accelerates the gathering and processing of data and information needed to make informed business decisions.

Tax Disputes and Rulings

Globally, tax authorities are becoming more sophisticated than ever - sharing information, scrutinising tax positions closer to real time, employing data analytics, requesting considerable volumes of information such as emails, and adopting a distinctly more savvy approach to dispute strategy.  New Zealand’s Inland Revenue is no different, and its confidence has been buoyed by a string of successes in the courts.  As Inland Revenue increases its activity levels across all sectors, minimising or eliminating the potentially significant cost and disruption of tax disputes is front of mind for business.

Our Tax Disputes and Rulings team has its finger firmly on the pulse, leveraging our depth of expertise and extensive know-how to efficiently, pragmatically and strategically manage - and sensibly resolve - tax disputes for our clients.  The team also identifies and addresses tax risk as transactions are being implemented, including through securing the comfort that a binding ruling or indicative view can provide.

Our local and global specialists can:

• assist with Inland Revenue risk reviews, investigations and audits, and co-ordinate forensic (discovery and analytics) support for information requests.  
• manage the entire tax dispute process, including settlement negotiations and relevant aspects of litigation support;
• offer Tax Controversy Management software to help multinational companies consistently control and manage tax controversies across multiple jurisdictions;
• seek private/product rulings or indicative views from Inland Revenue, and liaise with appropriate officials where tax outcomes do not resonate from a policy perspective.

For more information on how our Tax Disputes and Rulings team can keep your focus on operating and growing a successful business, please contact Campbell Rose or Patrick McCalman.

Tax audit strategy and consulting

For companies looking to proactively structure their systems and processes to minimize tax controversy risk, Deloitte Legal has extensive experience in multiple jurisdictions.  With an in-depth understanding of the internal processes and procedures of regulators and authorities, Deloitte Legal lawyers and tax controversy specialists are adept at delivering an informed and practical perspective on tax and statutory requirements.

Deloitte Legal assists businesses' effectiveness in preparing for and managing tax examinations. Our services include helping companies review pre-filing agreements, reportable transaction disclosures, voluntary disclosure and record retention processes. We develop or enhance programs, supporting internal controls and also provide training for the business' employees. Deloitte Legal has a strong reputation for its progressive insight into the key current trends in tax policy and tax audit procedures.

Tax controversy lifecycle management

Businesses are facing an increasing number of tax and regulatory requirements imposed by the countries in which they operate. Tax authorities are becoming more sophisticated in how they target high profile, high risk areas and are enhancing cross-border cooperation with other authorities, including coordination of joint tax audits. Deloitte and Deloitte Legal’s worldwide tax controversy practices include lawyers and tax specialists who provide strategic advice and tactical support to businesses in all facets of the tax controversy lifecycle.

We focus on efficiently and cost effectively helping companies address to their individual tax audit needs in multiple jurisdictions. Our approach to tax audit management helps businesses enhance access to essential data, expedite responses to information requests and proposed tax adjustments, utilize in-house tax departments and local country controller resources more efficiently, and build greater consistency in the information provided to tax authorities.

Dispute resolution

When controversies or disputes arise, Deloitte Legal professionals provide assistance with:

• Appeals and other legal protests
• Developing technical arguments and drafting advisory opinions
• Reporting
• Representation and litigation with authorities
• Post appeals mediation
• Arbitration
• Settlement

By bringing negotiation experience with other industries and jurisdictions we can help companies advance negotiations with tax authorities and manage penalty exposures. Deloitte and Deloitte Legal teams specializing in dispute resolution include lawyers, accountants, auditors, economists, former government officials, and industry specialists. By developing a thorough understanding of each company's specific challenges and aligning dedicated specialists Deloitte Legal can bring the right resources to the issue.