Tax Disputes

Increased transparency requirements have pushed the management of tax risk higher up companies’ agendas. Juan Ignacio de Molina, Yoshihiro Adachi, and Carlos Serrano of Deloitte explain how corporate governance and cooperative programmes can help.

Sophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.

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.