Special report: Tax controversy trends to monitor in 2023

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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

Special report: Tax controversy trends to monitor in 2023

Gavel leaning against a row of law books

ITR looks at the most important trends in tax controversy and how taxpayers can best adapt their strategies for potentially costly disputes.

Multinational companies are battling new sources of controversy from around the world, while old problems are not going away either.

Every business fears the possibility of a major court case costing its reputation and much more financially. Tax controversy is one of the hottest areas of corporate litigation since governments and tax authorities have cracked down on tax avoidance.

With exclusive insight from leading tax professionals at companies and advisory firms globally, this special report looks at how business and tax leaders can:

· Mitigate and manage tax controversy;

· Prevent and resolve disputes; and

· Review the implications of major cases

Here, we have a three-part special report written by Euan Healy, Josh White and Ralph Cunningham:

· Top tax controversy cases in 2023, so far

· The changing face of dispute strategy

· Why more tax controversy is in the offing

The first part is a feature looking at the most important tax disputes in 2023, followed by an article on dispute prevention and resolution strategies. The third part is an analysis of the driving factors of tax controversy.

This is the second in a series of ITR special reports on the most important issues in international tax. You can read the previous one here.

more across site & shared bottom lb ros

More from across our site

The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
Gift this article