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PwC Bygget, Bjørvika

12th Floor, Hung Tai Financial Plaza

Mark Whitehouse and Simon Wilks PwC Legal and PwC There have been a number of features of the UK tax dispute landscape over the course of the past year which are worthy of note. In the first instance, the UK's Public Accounts Committee (PAC) has taken a keen interest in tax compliance and tax avoidance. The enquiries of the PAC have included within their remit a number of important issues for large corporate groups. The PAC has summoned large corporate entities to discuss their tax affairs, including corporate groups such as Starbucks, Google and Amazon. The result of this is that this has created an environment in which many large corporate groups find their tax affairs under unusually high scrutiny.

Zeki Gündüz PwC Recent revisions in tax and customs legislation are significant as they indicate the adoption of a taxpayer rights-centric approach. On the one hand, the legislature sought to meet criticisms regarding the principles of equality and the rule of law. On the other, it sought to reform the tax administration to make it more efficient and to bring it under stricter control.

HMRC is consulting on further measures to tackle aggressive tax avoidance, including proposals to fine promoters of tax avoidance schemes up to £1 million ($1.5 million), leaving some tax advisers at risk.

Alberto Benshimol

1675 Broadway

Chinawat Assavapokee

Lower Mosley Street

Joel Williamson, Charles Triplett and Jason Osborn of Mayer Brown On February 12 2013, the OECD published its report on Addressing Base Erosion and Profit Shifting (the BEPS report). The BEPS project is remarkable due to its backing by the political leaders of the world's largest economies. It was commissioned by the G20 in 2012 as these governments scramble to preserve and recover corporate tax revenue, which declined sharply during the down economy years, from 3.8% of OECD members' combined GDP in 2007, to 2.9% of GDP in 2010. Beginning with the bold statement that "[b]ase erosion constitutes a serious risk to tax revenues, tax sovereignty and tax fairness for OECD member countries and non-member countries alike," the BEPS report identifies a number of key pressure areas where multilateral action may be needed. These include: