Tax controversy
Tax has become increasingly connected — governments are collecting and sharing taxpayer information, and tax changes in one jurisdiction can now trigger changes across the globe. The result is that tax controversy is evolving from two-sided disagreement in specific countries into a multi-dimensional, multi-country dynamic.
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What EY Law can do for you
Businesses must act so that their people, policies and systems are keeping pace. They need a line of sight into the issues and the potential for future tax controversy as well as a centralised global strategy. Should disagreements arise, having resources that can act as a “bridge” between the tax authorities and the company is essential.
Our lawyers have diverse backgrounds in the private and public sector, locally and overseas, and are experienced in acting both for and against tax authorities. Through our close working relationship with professionals in EY, we can take a broad and commercial view of tax risk, audits, disputes and advice. This differentiates the focus of EY Law tax practice from other tax legal practices.
We are instructed on many major tax audits and disputes, with our experienced teams taking matters beyond the formal dispute phase, through to discovery and litigation. Our approach to managing tax disputes focuses not only on the tax period in dispute, but also on obtaining certainty around tax risk.
Many taxpayers do not want to progress their tax cases to court for reputational reasons. We have an impressive record of efficiently resolving tax disputes with tax authorities before litigation, negotiating pragmatic taxpayer-friendly settlements based on our thorough understanding of the tax, accounting and commercial outcomes, while maintaining confidentiality.
We can also assist you with competent authority requests, MAP, voluntary disclosures, advice on contentious tax issues (including avoidance) and tax structuring.
Drawing on our contentious background, we are experienced in tax risk mitigation (for example, through binding rulings), tax governance and tax transparency. With tax governance being a current focus of Inland Revenue, we work with clients in documenting and implementing their Tax Governance Frameworks and testing controls to reduce the risk of incorrect tax positions being taken and to foster a culture where tax risk is managed throughout the organisation.
The outcome
Our specialised team helps you navigate controversy to achieve certainty. As well as helping you avoid controversy in the first place, we can assist you to respond to queries and seek to resolve audits and disputes in a timely and cost efficient manner. Where matters cannot be resolved, we can advise you on settlement strategies and negotiations or represent you before the courts and tribunals to get a final decision on the issue.
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