Deloitte EMEA Regional Profile (Tax Controversy)

Practice overview:

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 several 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 experience 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.

Awards and recognition:

2022 International Tax Review (ITR) European Tax Awards:

Deloitte in EMEA won 32 awards, including regional awards: EMEA Tax Firm of the Year and EMEA Tax Compliance & Reporting Firm of the Year for the sixth consecutive year. The network received the EMEA Tax Innovator Firm of the Year for the third consecutive time. Other regional distinctions include Diversity Equity and Inclusion Firm of the Year, Indirect Tax Firm of the Year, Tax Policy Firm of the Year, and Tax Technology Provider of the Year.

Jurisdiction Awards, in the EMEA region, include:

- National Tax Firm of the Year awards: Africa, Austria, Belgium, Bulgaria, CEE, Romania

- National Transfer Pricing Firm of the Year awards: Austria, Baltic States, Belgium, CEE, Denmark, Finland, Germany, Ireland, Luxembourg, Middle East, Norway, Portugal, Sweden

- National Tax Disputes Firm of the Year awards: Poland, Romania

- National Indirect Tax Firm of the Year awards: Germany, Luxembourg

Recognized leaders:

Euromoney and International Tax Review – Expert/Leaders guides: Over 250 leaders across the EMEA region were recognized for their individual abilities, as well as for their in-depth capabilities, experience, and knowledge:

• 77 leaders in Euromoney’s 2022 Tax Experts Guide

• 215 leaders in ITR’s 2022 World Tax Guide

2023 World Tax and World Transfer Pricing tier rankings:

- World Tax: Deloitte received more tier one (86) and tier two (52) rankings than ever before.

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