Tax Disputes

Eddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.

Luis Coronado and Matt Andrew of EY unpick the OECD’s consultation documents related to tax certainty under pillar one and find that there are many unresolved issues in terms of tax dispute resolution.

The indicators point in one direction: an increase in tax controversy, as authorities’ resources are ploughed into increased scrutiny. Luis Coronado of EY explains why, and suggests what tactics businesses should be adopting.