The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Sponsored
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Sponsored by Lakshmikumaran & SridharanThe Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan -
Sponsored by DeloitteJess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions
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Sponsored by DeloitteDeloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead
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Mariano Ballone
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Welcome to the 2018 edition of the Tax Controversy Leaders guide from the International Tax Review. This is the eighth annual publication of the list of the world's leading tax controversy practitioners and marks a significant step in its evolution. Beginning this year, we are looking to grow the guide in both scope and scale. It will cover more jurisdictions, reach out to more individuals and recognise more practitioners than ever before – from rising stars just making a name for themselves to market leaders with decades of experience behind them
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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.
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In recent times, the most significant change to the tax controversy landscape has been the increase in information provision requirements of taxpayers and the increase in interaction of revenue authorities across the region through information sharing and mutual assistance regimes. In addition, developments in data technology have given rise to greater coordination between different authorities within countries and across the Asia-Pacific region.
