Tax Certainty & Controversy

Tax disputes between taxpayers and local tax authorities are on the rise. During recent years (i.e. 2006 – 2019) there has been a substantial increase in MAP cases (i.e. from 2352 to 6955). The MAP statistics show that transfer pricing disputes are often the primary cause for double taxation, and eventually lead to MAPs. It is expected that, in coming years, increasingly complex and vague rules and regulations, growing information sharing and cooperation between local tax authorities, as well as government budget constraints, will further increase the risk of double taxation and tax disputes.

Tax certainty and controversy services are an integral part of all WTS member firm’s comprehensive service offering. Our professionals assist taxpayers during tax audits and represents them in negotiations with the local tax authorities, whenever possible, and before national tax courts, including hearings with judges and oral submission of the defence before these courts. Given our practical expertise in all aspects of tax law, our professionals can offer a unique combination of in-depth knowledge of both material and formal tax law.

Our integrated approach starts long before the actual dispute resolution takes place, by identifying the main risks and by devising defence strategies. Practice has shown that proactively identifying main tax risks and managing the defence strategies are essential if taxpayers want to avoid getting trapped in time-consuming dispute resolution processes.

Our tax certainty and dispute resolution services include (but are not limited to):

Tax certainty services, including:

• negotiation and conclusion of tax rulings and advance pricing agreements
• identification of important risks and preparation of defence files

Tax audit support services, including:

• support in discussions with the local tax auditors

Tax dispute resolution services, including:

• management of the dispute resolution process with the local tax authorities
• preparation of relevant documents and substantiations

WTS Global’s Tax Certainty and Controversy Service Line consists of tax and legal experts located in more than 100 countries. Our professionals have unique and vast experience in the field of tax certainty and (cross-border) tax dispute resolution. Many of our professionals have prior work experience at the tax authorities in their jurisdictions and therefore have in-depth knowledge of the procedures and working methods of the local tax authorities.