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

While rarely the sole driver of a combination, tax is becoming an increasingly important part of firms' efforts to keep up with client expectations
New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
Gift this article