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Tax Controversy

Confidently manage tax controversy

Bringing together the best teams, insights and technology 

Tax controversies typically are unique, urgent and inconvenient. Without guidance, the right technology and coordination, multinational organisations can spend enormous amounts of time and resources addressing tax disputes across jurisdictions.

Through decades of working on a broad range of tax issues, we have fine-tuned our technology, analytic procedures and response methodologies to offer scalable solutions tailored to each client and tax controversy.

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.  

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How we can help:


  • Planning and preparation to minimise disputes
  • Documenting and preparing 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
  • Obtaining and negotiating tax authority rulings


  • Tax authority enquiry handling and closure
  • Global enquiry 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
  • Mediation and alternative dispute resolution techniques
  • Litigation representation (in certain countries)

  • audit readiness assessment and preparation;
  • strategies to minimise the impact of tax controversies;
  • 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. 

Operate with dynamic control

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