International Tax Review received a record number
of nominations this year for the 2017 Tax Controversy Leaders guide, reflecting
the increasing amount of expertise in dealing with complex tax
matters during a time of heightened controversy, with
multinationals and tax authorities around the world busy
challenging or defending tax strategies and viewpoints at
various stages of a dispute.
The global tax controversy landscape is only going to get
more complex. As taxpayers and authorities adjust to new
standards and mechanisms, enhanced enforcement actions, new
reporting requirements, automatic exchange of information, and
multilateral risk assessment processes are likely to lead to
increased audits and disputes, creating new challenges and
corresponding uncertainty for taxpayers.
Aside from BEPS, state aid cases in the European Union,
disputes arising from the controversial diverted profits tax in
the UK and Australia, and maybe soon New Zealand too, are
creating debate over the right approach to tax practices.
Moreover, new indirect tax regimes in India and the Gulf
Cooperation Council's member states will inevitably lead to
disputes that will ultimately evolve how the rules are applied.
In the US, meanwhile, the Internal Revenue Service continues to
pursue transfer pricing issues and is aggressively litigating
such cases. However, its loss against Amazon showed it cannot
always win, and its pending appeal against Medtronic's TP
practices will once again raise debate and interest in TP
Reliable expert advice regarding such tax disputes and
litigation has never before been more valuable for businesses
and governments alike.
With all of this in mind, it is clear that taxpayers need
access to lawyers and advisers with experience in all stages of
tax controversy. The remit of tax controversy advisers now
extends far beyond the courtroom with many taxpayers seeking
advice on tax dispute prevention techniques. In addition, many
tax controversy advisers provide services on tax audit
management practices, global strategic planning of tax audits
and disputes, tax risk management, analysis and disclosure,
mutual agreement procedures, advance pricing agreements and
alternative tax dispute resolution.
Therefore, International Tax Review presents this
seventh edition of the Tax Controversy Leaders guide so you can
obtain reliable and trustworthy advice in each of the areas
highlighted above, in each of the 60 jurisdictions covered.