International Tax Review received a record number of nominations this year for the 2017 Tax Controversy Leaders guide, reflecting the increasing amount of expertise in dealing with complex tax matters during a time of heightened controversy, with multinationals and tax authorities around the world busy challenging or defending tax strategies and viewpoints at various stages of a dispute.
The global tax controversy landscape is only going to get more complex. As taxpayers and authorities adjust to new standards and mechanisms, enhanced enforcement actions, new reporting requirements, automatic exchange of information, and multilateral risk assessment processes are likely to lead to increased audits and disputes, creating new challenges and corresponding uncertainty for taxpayers.
Aside from BEPS, state aid cases in the European Union, disputes arising from the controversial diverted profits tax in the UK and Australia, and maybe soon New Zealand too, are creating debate over the right approach to tax practices. Moreover, new indirect tax regimes in India and the Gulf Cooperation Council's member states will inevitably lead to disputes that will ultimately evolve how the rules are applied. In the US, meanwhile, the Internal Revenue Service continues to pursue transfer pricing issues and is aggressively litigating such cases. However, its loss against Amazon showed it cannot always win, and its pending appeal against Medtronic's TP practices will once again raise debate and interest in TP matters.
Reliable expert advice regarding such tax disputes and litigation has never before been more valuable for businesses and governments alike.
With all of this in mind, it is clear that taxpayers need access to lawyers and advisers with experience in all stages of tax controversy. The remit of tax controversy advisers now extends far beyond the courtroom with many taxpayers seeking advice on tax dispute prevention techniques. In addition, many tax controversy advisers provide services on tax audit management practices, global strategic planning of tax audits and disputes, tax risk management, analysis and disclosure, mutual agreement procedures, advance pricing agreements and alternative tax dispute resolution.
Therefore, International Tax Review presents this seventh edition of the Tax Controversy Leaders guide so you can obtain reliable and trustworthy advice in each of the areas highlighted above, in each of the 60 jurisdictions covered.
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