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Tax Controversy

Manage Tax Disputes with Confidence

Guidance, strategy and support for local and global challenges with tax disputes.

Confidently manage tax conflicts with global tax authorities

Tax disputes are usually unique, urgent and uncomfortable. Without proper guidance and coordination, multinational organisations can spend huge amounts of time and resources addressing tax disputes across multiple jurisdictions. In today's tax landscape, where authorities examine technical merit and analysis as well as implementation and motive, you need knowledgeable and experienced specialists to provide detailed and tailored solutions.

Through decades of experience with a wide range of tax issues, we have refined our technology, analytical procedures and response methods so that we can provide a widely deployable, scalable solution that we can tailor to each client and tax conflict.

Deloitte's Tax Controversy team consists of professionals with a range of skills and experience, including former tax administration staff, alternative dispute resolution experts, in many countries, tax dispute specialists, all of whom support you through the conflict resolution cycle. We are active in all tax areas, including domestic income tax, international tax, Transfer Pricing, Indirect Tax and special areas such as incentives. In addition, in some markets, we also both represent at tribunals and courts. Services include assessment and preparation of audit readiness, strategies to minimise the impact of tax conflicts, support in reducing potential conflicts through tax authority ruling systems, support for international treaty proceedings, application of advanced pricing agreements (APAs) and other similar instruments.

How we can help you:


  • Planning and preparation to minimise conflict
  • Documenting and preparing evidence and defence files
  • Review and finalisation of controversy strategic policies around the world
  • Bilateral and multilateral Advanced Price Agreements (APAs)
  • Advanced Decisions and Unilateral APAs
  • Pre-transactional engagement with tax authorities
  • Ongoing proactive engagement with tax authorities
  • Obtaining and negotiating decisions from tax authorities


  • Handling and Closure of Tax Authority Enquiries
  • Worldwide follow-up of the application process
  • Negotiation with tax authorities
  • Analysis, economic and technical support
  • Professional and litigation support
  • Mutual agreement procedure (MAP) and arbitration support
  • Preparation of evidence, including witness interviews and gathering of evidence
  • Mediation and Alternative Conflict Resolution Techniques
  • Representation in court cases (in certain countries)

Operate with dynamic control

Deloitte's Tax Operate Services is your proven partner, working with you to stay ahead of regulatory changes, simplify compliance, leverage technology and data, and improve your Tax function.