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Deloitte Tax Controversy

Current trends suggest that multinational organisations and individuals will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on implementation. Deloitte's tax dispute resolution teams include former tax authority officials, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses at all phases of the tax dispute resolution cycle.

Deloitte’s tax controversy team supports a full spectrum of clients ranging from multinational corporations to individuals on a range of contentious tax matters.

The team brings together leading practitioners from Deloitte’s tax advisory, legal and risk advisory teams.

With a team that is made up of tax specialists, accountants, solicitors, economists, former HMRC inspectors, data analysts and information technology experts, we achieve successful outcomes through risk management consulting, negotiation, alternative dispute resolution, and litigation.

We advise on domestic and international matters, and have active engagements in the following areas:

  • Settlement of tax disputes as part of HMRC’s High Risk Corporates Programme and the Profit Diversion Compliance Facility
  • Collaborative dispute resolution on numerous enquiries, including Transfer Pricing and Diverted Profits Tax; Expenses of Management; Residence, Permanent Establishments and Controlled Foreign Companies;
  • Avoiding transfer pricing controversy through Advanced Pricing Agreements and resolving transfer pricing controversy through Mutual Agreement Procedures.
  • Complex personal tax enquiries including domicile positions and trust status
  • Investigations under Code of Practice 8 and 9
  • Voluntary disclosures to HMRC 
  • State Aid challenges
  • Technology enabled handling of HMRC document and information requests
  • Negotiations and appeals on discovery assessments, penalties and closure notices
  • Alternative Dispute Resolution in relation to direct and indirect tax matters 
  • Litigation (from First-tier Tribunal to the Supreme Court)
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