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Deloitte Tax Controversy
Current trends suggest that multinational organisations and individuals will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on implementation. Deloitte's tax dispute resolution teams include former tax authority officials, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses at all phases of the tax dispute resolution cycle.
Deloitte’s tax controversy team supports a full spectrum of clients ranging from multinational corporations to individuals on a range of contentious tax matters.
The team brings together leading practitioners from Deloitte’s tax advisory, legal and risk advisory teams.
With a team that is made up of tax specialists, accountants, solicitors, economists, former HMRC inspectors, data analysts and information technology experts, we achieve successful outcomes through risk management consulting, negotiation, alternative dispute resolution, and litigation.
We advise on domestic and international matters, and have active engagements in the following areas:
- Settlement of tax disputes as part of HMRC’s High Risk Corporates Programme and the Profit Diversion Compliance Facility
- Collaborative dispute resolution on numerous enquiries, including Transfer Pricing and Diverted Profits Tax; Expenses of Management; Residence, Permanent Establishments and Controlled Foreign Companies;
- Avoiding transfer pricing controversy through Advanced Pricing Agreements and resolving transfer pricing controversy through Mutual Agreement Procedures.
- Complex personal tax enquiries including domicile positions and trust status
- Investigations under Code of Practice 8 and 9
- Voluntary disclosures to HMRC
- State Aid challenges
- Technology enabled handling of HMRC document and information requests
- Negotiations and appeals on discovery assessments, penalties and closure notices
- Alternative Dispute Resolution in relation to direct and indirect tax matters
- Litigation (from First-tier Tribunal to the Supreme Court)
Spotlight
Alternative Dispute Resolution
Alternative Dispute Resolution is a flexible process which has been introduced by HMRC in an attempt to resolve tax disputes more effectively. Mediation, which is also commonly referred to as ‘facilitation’ by HMRC, falls under the Alternative Dispute Resolution umbrella and has become increasingly popular and successful as a cost effective, consensual and efficient means of resolving tax disputes.
Tax disclosure and transparency
The last decade has seen significant tax and regulatory change, including the introduction of global information exchange programmes like the Common Reporting Standard, new and increased penalty regimes for offshore tax compliance errors, proposals to extend HMRC’s powers to assess tax and issue formal information notices, the introduction of the Criminal Finances Act and the ongoing complexity and development of the UK tax system. At the same time, a decrease in HMRC staff numbers has seen HMRC develop a new, data-analytics focused approach to tax enquiries.
Direct Tax Dispute Resolution and Litigation
Whether your business is currently in a dispute with HM Revenue & Customs or is anticipating a dispute, there are a number of ways in which we can help. Litigation can be an effective means of resolving disputes where both parties have reached an impasse.
However, increasingly Alternative Dispute Resolution is being used successfully by taxpayers and HMRC to resolve complex and long-running disputes. Deloitte can draw on many years of experience to assist you with either approach.
Insights
- Profit Diversion Compliance Facility (“PDCF”) – what it is and tips for success September 2021
- Tax Controversy: Understanding The Routes To Resolution 26 November 2019 - Webinar
- Transfer Pricing Controversy: Dispute Prevention - Advance Pricing Agreements (APAs) 9 October 2019 - Webinar
- Tax Controversy: Key Concepts For Navigating An HMRC Enquiry 24 September 2019 - Webinar
- Unallowable Purpose - The State Of Play 19 September 2019 - Webinar
- Deloitte/HMRC Joint Webcast On The Profit Diversion Compliance Facility 10 July 2019 - Webinar
- Developments in HMRC’s formal information powers 17 May 2019 - Article Briefing document
- HMRC information powers 29 April 2019 - Deloitte Briefing
- Transfer pricing controversy, strategy and future direction 16 April 2019 - Article
- Chicken or the egg: TP, BEPS, and local-country legislation 19 February 2019 - Article
- Transfer pricing controversy: From best endeavours to binding arbitration: Eliminating double taxation 14 February 2019 - Article
- Transfer pricing controversy in 2019 14 February 2019 - Article
