How is your multinational enterprise anticipating changes and conflicts regarding taxes? As part of the OECD / G20 BEPS (Base Erosion and Profit Shifting) project, more than 135 countries are working together to put an end to tax avoidance strategies that make use of loopholes and mismatches between the tax laws of the different countries. Far-reaching anti-abuse provisions are now being inserted into their treaties and laws. The OECD is now working on new rules to spread the profit of multinationals across countries and on an agreement on a worldwide minimum tax rate. These rules are expected to be highly complex and will increase the risk of multiple taxation. We can assist your management in developing a worldwide strategy for being tax compliant and therefore minimise the tax risks in accordance with the goals of your enterprise.
Tax authorities around the world are intensifying their inspections and are exchanging tax information both within and outside the EU. This will inevitably lead to more national and international conflicts. A great deal of technical expertise is needed to deal with these developments effectively, and it is essential that you are well prepared. Conflicts can be prevented or resolved faster and more effectively by taking preventative measures and opting for the right methods. We can offer you worldwide support in managing tax inspections and avoiding and resolving tax conflicts. PwC has a Global ‘Tax Controversy and Dispute Resolution’ (TCDR) network of experts active in all relevant areas in more than 80 countries. You can read more about this on the website of PwC Global.
We will prepare your enterprise for any possible conflicts. We will assist your management in analysing potential tax risks to which the enterprise is exposed in various countries and in developing a worldwide strategy to minimise those risks. We will do this in cooperation with your own specialists and the experts in our international network, such as our transfer pricing specialists. We will assess your international group structure against the policy spearheads of national tax authorities and assist you in documenting your tax positions so that they can protect your enterprise in the case of inspections and conflicts.
PwC can help you by obtaining advance security (APAs, rulings) and supporting you for tax authority inspections and preparing for inspections. Furthermore, we can help you in drawing up and concluding settlement agreements, thereby avoiding drawn-out conflicts and expensive legal procedures. We can advise you on your rights and obligations in international data exchanges by tax authorities and will support you during joint audits.PwC can help you to gain certainty in advance (APA’s, rulings) and assist you with (preparations for) audits by the tax authority, which includes establishing settlement agreements. This can help to avoid protracted conflicts and expensive legal proceedings. We can also advise you about your rights and obligations during international information exchanges by tax authorities, and assist you during ‘joint audits’.
Should a conflict nevertheless become avoidable, there are a number of avenues, both at the national and international level, that can be taken to resolve it. PwC can advise you in this regard. Furthermore, PwC can support you in proceedings before the national tax court or the European Union’s Court of Justice, but also during international consultations or arbitration procedures (MAPs). Our worldwide network of experts includes legal and economic specialists, including dozens of former employees of government authorities and tax services who are able to offer support based on their broad knowledge and experience. We also look at alternative options and mechanisms to settle disputes involving bilateral, multilateral and international treaties, such as trade treaties.
If your organisation is undergoing transformations. This could include mergers, acquisitions, international restructuring, the revision of the supply chain, etc.
If you want to be a step ahead of conflicts with tax services by having your group structure assessed and organising a documented defence.
If your organisation is about to be audited and you want to set up a decent audit management.
If you need support with a payment dispute during a litigation process or consultation procedure.
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