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The Deloitte network of member firms in the Americas deploys the applicable local and regional teams quickly. Deloitte's Americas tax controversy teams consist of more 280 professionals with offices in 130 locations through a network of member firms.
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The Americas have recently seen a number of changes that will impact controversy matters. In December 2017, certain countries passed major tax legislation and there is an increased need for the use of alternative dispute resolution strategies to preclude the need of entering costly and unnecessary litigation. Additionally, funding across the taxing authorities varies greatly and will have an impact on the compliance approaches that the authorities may take to encourage voluntary compliance and deploy resources to the most significant non-compliance. Appropriate funding coupled with recently enacted tax legislation will likely impact the way audits will be conducted in the Americas.
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Current trends suggest that multinational organisations will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and are increasingly focusing on not only the technical merit of a tax position but also on its implementation.
Sponsored Features
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
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Sponsored by DeloitteInterview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic
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Sponsored by CuatrecasasA recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas
Special Focus
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
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Sponsored by DeloitteCarlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente explain how Italy classifies payments for software distribution and the potential consequences in the event of a tax audit
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosSofia Araújo Alves of Morais Leitão, Galvão Teles, Soares da Silva & Associados explains the Carbon Border Adjustment Mechanism’s transition to its definitive phase, highlighting new compliance requirements, thresholds, and regulatory simplifications
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Sponsored by MDDPMonika Marta Dziedzic and Paweł Wyciślik of MDDP outline how 2026 marks a shift towards digital tax compliance in Poland, with mandatory e-invoicing, enhanced reporting obligations, and targeted reforms shaping the year ahead