Deloitte
EMEA
Tax authorities continue to innovate, not only opening more enquiries, but also exploring new types of data-led tax audits. As such, multinational organizations continue to spend more time and resources managing tax controversies in both their local and foreign jurisdictions, with a view to both the financial and reputational aspects of a tax dispute.
Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on implementation. Research suggests that the average length of a tax audit has risen in recent years. As a result of these trends, organizations and tax authorities are increasingly taking disputes to court and the past 12 months have seen a number of significant judgements across the region.
Deloitte's tax controversy teams include former tax authority officials, tax specialists, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses at all phases of the tax controversy cycle.
In the EMEA region, a strong network has been created that is ready to assist multinational enterprises navigate the various procedures and provide strategic guidance in addition to detailed legal analysis. Deloitte controversy specialists assist clients proactively across pre-dispute, dispute and litigation matters.
Our key service offerings include:
• Pre-controversy audit readiness and data examination
• Voluntary disclosures
• Negotiated settlements
• Litigation, appeals, and settlement
• Transfer pricing
• Tax controversy software tools and support
• Corporate defense
Recent wins:
• Corporate defense for a large multinational in the consumer sector against alleged failure to comply with supervisory duties regarding its tax function. The underlying allegations evolved during tax field audits. The defense required combined tax and legal expertise and resulted in settlements in favor of the taxpayers.
• Represented a major media company in a VAT hearing on the VAT rating for electronic newspapers. The win for the taxpayer could have far-reaching effects on the VAT treatment of a range of digital newspapers and other digital publications, benefiting publishers of all sizes.
• Successfully represented a corporate group in litigation that was heard at all levels of the UK tax courts and was referred to the CJEU, on the fiscal neutrality between virtual and physical slot machines.
• Case in the German Federation Fiscal Court and CJEU involving the interaction of German real estate transfer tax law and European State Aid law.
• Case referred to the CJEU regarding German dividend withholding tax and violation of EU fundamental freedoms.
• A landmark win in the Dutch courts that reintroduced the rights of Dutch taxpayers to appeal against any decision relating to the actual or envisaged exchange of information by the Dutch tax authorities.
• Assisting an industry leading Multinational company manage a Transfer Pricing Revenue Audit including the preparation for the Tax Appeal Commission by virtue of the raising of amended assessments by the Irish Tax authorities.
• Assisting a client in the aircraft leasing industry defend its VAT recoverability position arising from the supply of loans in a case that will have widespread significance for the industry.
• Acted for a number of large corporates in the UK’s High Risk Corporate Programme.
Awards and recognition:
2020 ITR European Tax Awards:
Deloitte in EMEA won 21 awards, including regional awards: Tax Firm of the Year and Compliance & Reporting Firm of the Year for the fourth consecutive year and Tax Innovator Firm of the Year.
National Tax Firms of the Year: Austria, Central and Eastern Europe, Cyprus, Luxembourg, Malta, Norway, Russia, Switzerland and Ukraine
National Transfer Pricing Firms of the Year: Austria, Baltics, Belgium, Denmark, Portugal, Spain and Switzerland
2020 Euromoney World Tax Guide: Deloitte’s Tax practices in the region were ranked tier 1 in 27 jurisdictions and tier 2 in 15 jurisdictions.
2020 ITR World Transfer Pricing Guide: Deloitte’s Transfer Pricing practices in EMEA were ranked tier 1 in 28 jurisdictions.
2020 ITR Leader Guides: A total of 270 leaders from Deloitte were listed in the Indirect Tax, Tax Controversy and Women in Tax Leaders guides, respectively.
2020 Euromoney Tax Advisers Guide: 84 Tax practitioners from different countries in the region were recognized by the Tax Experts Guide.
2019 Euromoney Transfer Pricing Advisers Guide: 58 Transfer Pricing specialists from different countries in the region were recognized by the Transfer Pricing Experts Guide.
Phone: +44 20 7007 2737
Email: matbatham@deloitte.co.uk
Twitter: @Deloitte
Website: Deloitte.com/tax
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