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Introduction

Methodology

Tax Controversy Leaders is a guide to the leading tax dispute resolution lawyers and advisers in the world. In addition to highlighting tax professionals, the guide also includes litigators and barristers who may not practice tax on a day-to-day basis.

Inclusion in this guide is based on a minimum number of nominations received. Besides the required number of nominations, entrants must also possess evidence of outstanding success in the past year and consistently positive feedback from peers and clients. Firms and individuals cannot pay to be recommended in the Tax Controversy Leaders guide.

We are witnessing 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.

As such, litigation experts are increasingly in demand.

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 matters.

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.

We hope that this seventh edition of the Tax Controversy Leaders guide will provide you with the confidence to obtain reliable and trustworthy advice in each of the areas highlighted above, in each of the 60 jurisdictions covered.

Anjana Haines,

Editor, International Tax Review

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