Skip to main content

Tax Disputes & Rulings

Confidently manage tax disputes and obtain valuable tax certainty

Guidance, strategy, and support for local and global tax dispute challenges, and securing certainty via binding rulings or other Inland Revenue offerings. 

Confidently manage tax controversy with tax authorities globally

Tax audits and disputes typically are unique, urgent, inconvenient and distracting. Without proper guidance and coordination, multinational organisations can spend enormous amounts of time and resources – and suffer from corresponding business disruption – addressing non-routine tax authority interactions across jurisdictions. In today’s tax landscape, where authorities investigate technical merit and analysis as well as implementation and motive (including harnessing the power of data analytics tools and related technology), you need experienced, knowledgeable specialists to provide a strategic and customised solution.

Through decades of working on a broad range of tax issues, we have fine-tuned our technology, analytic procedures, and response methodologies to offer a broad-based, scalable solution that we can tailor to each client and tax dispute.

Deloitte's tax dispute teams include individuals with a range of skills and experience, including former tax administration employees, alternative dispute resolution professionals, and, in many countries, tax litigation specialists, all supporting you throughout the tax dispute resolution cycle. We work across all tax fields, including domestic income tax, international tax, transfer pricing, indirect tax, and specialty areas such as incentives; in some markets, we also provide tribunal and court representation. Services include audit readiness assessment and preparation (including tax “health checks”); strategies to minimise the impact of tax disputes; support for mitigation of potential disputes through revenue authority ruling systems; support for international treaty procedures; application of advanced pricing agreements (APAs), and other such tools.

How we can help:

  • Planning and preparation to minimise disputes, including tax “health checks” and reviews.
  • Documenting and preparing contemporaneous transaction support, evidence and defence files.
  • Reviewing and finalising global strategic controversy-aware policies.
  • Bilateral and multilateral advanced pricing agreements (APAs).
  • Advanced rulings and unilateral APAs.
  • Pre-transaction engagement with tax authorities.
  • Ongoing proactive engagement with tax authorities, including through section 113 requests, voluntary disclosures, IR282 statements in support of tax position and liaising with tax policy officials where circumstances dictate.
  • Obtaining and negotiating tax authority rulings, indicative views and other related products.
  • Tax authority inquiry handling and closure (from risk review and audit through to formal disputes), including co-ordinating forensic (discovery and analytics) support for information requests.
  • Global inquiry process tracking.
  • Negotiation with tax authorities.
  • Analysis, economic and technical support.
  • Appeal and litigation support.
  • Mutual agreement procedure (MAP) and arbitration support.
  • Evidence preparation including witness interviews and discovery (in certain countries).
  • Mediation and alternative dispute resolution techniques.
  • Litigation representation (in certain countries).

Operate with dynamic control

 

 

Deloitte’s Tax Operate service is your proven provider, working with you to stay ahead of regulatory changes, simplify compliance, harness technology and data, and elevate your tax function.

Learn more