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Tax Controversy Leaders: Introduction

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 practise tax on a day to day basis.

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 practise tax on a day to day basis.

Inclusion in Tax Controversy Leaders is based on a minimum number of nominations received. Besides the required number of nominations, entrants into the guide must also possess (1) evidence of outstanding success in the last year; and (2) consistently positive feedback from peers and clients. Firms and individuals cannot pay to be recommended in Tax Controversy Leaders.


The need for advice from professionals with expertise in tax disputes is more important than ever as governments and tax authorities are becoming more aggressive in their search for revenue. In this type of environment, where all deals are facing increased scrutiny, it is crucial that taxpayers have access to practitioners with experience in all stages of tax controversy, including pre-audit, audit, administrative appeals, and litigation.

Tax controversy work is heating up around the world. In the US for example, codification of the economic substance doctrine into the Tax Code has meant that this issue will continue to be litigated. Advisers that have experience defending against assertions that a transaction lacks economic substance will continue to be in high demand.

The number of transfer pricing cases is also unlikely to decrease. The tax treatment of intangible assets and intellectual property is an especially prevalent question in courts around the world, as are questions of shared headquarter services and cost-sharing arrangements.

Taxpayers that are planning cross-border transactions with these need advice on how to prepare their transfer pricing documentation to avoid ending up in a dispute with the tax authorities. Permanent establishment issues are also going to remain highly contested in transfer pricing disputes.

Issues concerning foreign tax credits, foreign source income, valuation of fixed and intangible assets, deferral, tax treaties and withholding tax will also continue to remain at the forefront of controversy work.

Taxpayers will need advice from lawyers and advisers that have experience across a number of venues. The litigators in this guide have experience not only at every level of the courts, but also in administrative proceedings, audits, appeals, and competent authority negotiations.

The practitioners listed here also have skills that extend beyond the courtroom. They also have experience in pre-trial matters including responding to third-party requests for information and summonses for tax accrual workpapers and other privileged documents. They are also familiar with document collection and analysis and preparation of expert testimony and reports, all of which can be invaluable when preparing to litigate.

The guide also includes experts in the mediation and arbitration of tax disputes, a process that is becoming increasingly common among governments, courts and regulatory agencies.

Erin Kelechava,

Editor, Tax Disputes Week

Contents

Argentina

Australia

Belgium

Brazil

Canada

China

Denmark

France

Germany

India

Italy

Japan

Malaysia

Mexico

The Netherlands

New Zealand

Norway

Portugal

Spain

Sweden

Switzerland

Thailand

UK

US

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