Special Focus
Tax Controversy Leaders 2011

Special Focus Archive

Argentina: Taxpayers strive to deflect scrutiny from authorities

The Argentine tax authorities have become more aggressive in recent years, particularly in transfer pricing matters, and have not been afraid to take legal action against taxpayers, reports Juan Manuel Soria Acuña of MCRLex
Australia: Australia deals with new methods of resolution

Anti-avoidance has been the battleground in the courts in litigation between taxpayers and the commissioner of the Australian Taxation Office, report Stewart Grieve and Nasos Kaskani of Corrs Chambers Westgarth
Belgium
Brazil: Disputes over tax benefits and the position of Brazil’s Supreme Court
Canada: Recent developments in Canadian tax controversy and litigation
China
Denmark
France
Germany
India
Italy
Japan: Supreme Court affirms rule of law in Japanese taxation

Gary Thomas of White & Case reports on litigation that made clear that the Japanese tax authorities must have a legal basis for making an assessment and not rely on a tax avoidance argument
Malaysia
Mexico: Challenges and opportunities of litigation or settlement with the tax authorities

Manuel Sainz Orantes and Alejandro Torres Rivero of Chevez, Ruiz, Zamarripa y Cia discuss how tax litigation has changed in Mexico, noting that the tax authorities are complying more with the law. However, recent Supreme Court judgments have not always abided by legal provisions
The Netherlands
New Zealand
Norway
Portugal
Spain
Sweden
Switzerland
Thailand
UK: Tax controversy in the UK

Revisions of previous guidance is showing signs of a more conciliatory approach by the UK tax authorities. However they are still prepared to litigate, points out Helen Buchanan of Freshfields Bruckhaus Deringer
US: Back to the future for tax litigation

Joel Williamson, Scott Stewart, and Kelsey Arnold of Mayer Brown review some key themes, such as economic substance, from US tax litigation since the 1990s. They predict a return to traditional statutory and regulatory arguments in the tax cases of the future