Introduction

Methodology Tax Controversy Leaders is a guide to the leading tax dispute resolution lawyers and advisers in the world. In addition to highlighting tax professionals, the guide also includes litigators and barristers who may not practise tax on a day-to-day basis. Inclusion in this guide is based on a minimum number of nominations received. Besides the required number of nominations, entrants must also possess evidence of outstanding success in the past year and consistently positive feedback from peers and clients. Firms and individuals cannot pay to be recommended in the Tax Controversy Leaders guide.

Tax litigation experts are increasingly in demand as tax authorities around the world expand their resources to audit the tax affairs of big firms and challenge any irregularities.

Global trends this year have centred on how governments worldwide are implementing the OECD's recommendations in the base erosion and profit shifting (BEPS) project, leading to a number of disputes arising as taxpayers and authorities adjust to new standards and mechanisms.

In Europe, the European Commission's state aid investigations are unravelling agreements held between multinationals and governments. The European Commission's decision that requires Ireland to obtain $14.5 billion in back taxes from Apple over "illegal" state aid is just one example of a ruling against a US multinational enterprise in recent years. Apple and Ireland are appealing the Commission's ruling, as are Luxembourg and the Netherlands for the Commission's state aid decisions that went against Fiat and Starbucks, respectively, in October 2015. Moreover, the Danish government will investigate hundreds of taxpayers with potential undeclared offshore assets after announcing that it will purchase data leaked in the Panama Papers scandal. Reliable expert advice regarding such tax audits, investigations, disputes and litigation has never before been more valuable for businesses and governments alike.

In the US, the Internal Revenue Service continues to pursue transfer pricing issues and is aggressively litigating transfer pricing cases.

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.

We hope that this sixth edition of the Tax Controversy Leaders guide will provide you with the confidence to obtain reliable and trustworthy advice in each of the areas highlighted above, in each of the 53 jurisdictions covered.

Anjana Haines,

Editor, International Tax Review

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