Countries are changing tax laws and regulations due to the OECD/G20 BEPS (Base Erosion and Profit Shifting) project and other international developments. Their bilateral tax treaties and legislation now contain far-reaching anti-abuse provisions. Tax authorities are intensifying their audits worldwide and are exchanging information within the EU and beyond. This will inevitably lead to more national and international conflicts and means a lot of technical expertise is needed to effectively address the issue. But it is essential for you to be well prepared. By taking preventive measures and selecting appropriate methods, conflicts can be avoided or resolved faster and more effectively.
Want to know how your multinational company can anticipate tax-related conflicts? We can help your boards when developing a worldwide strategy for minimising tax risks in accordance with the objectives of your company. We can also offer you worldwide support when managing fiscal audits and preventing and resolving tax-related conflicts. PwC possesses a Global ‘Tax Controversy and Dispute Resolution’ (TCDR) Network of experts in all relevant disciplines in over 80 countries.
Preparing your company for potential conflicts. We can help your board to analyse the tax risks encountered by your company in various countries and to develop a worldwide strategy for minimising these risks. We will do this together with your specialists and the experts in our international network, like those in the field of transfer pricing. We will evaluate the international structure of your group against the requirements of national tax authorities and help you to document your fiscal positions so they can protect your company in case of audits and conflicts.
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’.
If a conflict cannot be avoided, various avenues are available for resolving it at national and international level. In this case, PwC can offer you the required advice. PwC can also assist you in litigation at national tax courts or at the Court of Justice of the European Union, as well as in international mutual agreement procedures (MAPs) or arbitration procedures. Our worldwide network of experts features legal and economic specialists and dozens of former professionals from governments and tax authorities, who can offer comprehensive support based on extensive knowledge and experience. We will also examine alternative dispute resolution mechanisms in bilateral, multilateral and international treaties like trade agreements.
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