Navigating the global tax disputes landscape

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Navigating the global tax disputes landscape

Sponsored by

sponsored-firms-kpmg.png
lighthouse-1313047.jpg

Aldo Mariani of KPMG International presents the key findings from an extensive survey of tax dispute professionals regarding the trends and developments in today’s tax environment, and how authorities are adjusting their approach.

The rise of tax authority activity

KPMG has produced a special report that takes an in-depth look at tax authorities worldwide and the global environment that in-house taxpayers are navigating today.

Based on an extensive survey of tax dispute professionals from KPMG firms, this report examines the trends and developments shaping the current environment and how tax authorities respond. Overall, the survey results show that companies are seeing a significant rise in tax audits and disputes, and all signs point towards even more intense tax authority activity in the future.

Click here to download the survey.

About the survey

The report charts the evolution of leading tax departments and identifies operational benchmarks for high-performing tax teams. It highlights the survey’s findings about issues facing tax authorities that include people, processes, and technology deployed by tax departments to manage their activities related to tax audits and disputes.

The findings in the report are based on a survey of over 115 tax dispute professionals from KPMG firms in 49 jurisdictions worldwide.

About 40% of respondents deal primarily with international companies, while 35% most commonly work with large domestic companies. The remaining respondents are focused on small business clients (15%) and individual clients (10%).

Key findings

  • Audit activity has been rising across the board for most taxes, with a special focus on multinational groups and large domestic taxpayers;

  • Audits are being approached more aggressively, and tax authorities seem more likely to employ harder-hitting powers to gather information, such as asserting formal access rights, conducting formal interviews and issuing summonses;

  • New and increased tax penalties are being enacted, and tax authorities seem to be applying them, as well as existing penalties, more frequently;

  • Technology is helping tax authorities to improve the evaluation of enormous volumes of available data that can help to identify and address significant compliance risks;

  • Disputes can be resolved through settlement in most jurisdictions, although many tax authorities tend to propose significant adjustments and expect taxpayers to concede the disputed amount; and

  • Critical factors influencing settlement include the amount of funds at stake, the impact of the available evidence, and the risk of litigation.

Read the original version of the article on KPMG’s website.

Click here to access more KPMG Future of Tax content.

more across site & shared bottom lb ros

More from across our site

ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
The hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
Join ITR's Head of Research, John Harrison, for an overview of key dates, new developments, best practices, and more for next year’s research cycle
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Gift this article