Special report: Tax controversy trends to monitor in 2023

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Special report: Tax controversy trends to monitor in 2023

Gavel leaning against a row of law books

ITR looks at the most important trends in tax controversy and how taxpayers can best adapt their strategies for potentially costly disputes.

Multinational companies are battling new sources of controversy from around the world, while old problems are not going away either.

Every business fears the possibility of a major court case costing its reputation and much more financially. Tax controversy is one of the hottest areas of corporate litigation since governments and tax authorities have cracked down on tax avoidance.

With exclusive insight from leading tax professionals at companies and advisory firms globally, this special report looks at how business and tax leaders can:

· Mitigate and manage tax controversy;

· Prevent and resolve disputes; and

· Review the implications of major cases

Here, we have a three-part special report written by Euan Healy, Josh White and Ralph Cunningham:

· Top tax controversy cases in 2023, so far

· The changing face of dispute strategy

· Why more tax controversy is in the offing

The first part is a feature looking at the most important tax disputes in 2023, followed by an article on dispute prevention and resolution strategies. The third part is an analysis of the driving factors of tax controversy.

This is the second in a series of ITR special reports on the most important issues in international tax. You can read the previous one here.

more across site & bottom lb ros

More from across our site

One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data
Despite a three-year-high in tax revenues generated from settling TP cases, HMRC reported a sharp fall in resolved MAP disputes
Inflexion’s proposed minority stake in Baker Tilly Netherlands could propel the firm in the Dutch market, CEO Ronald Hoeksel tells ITR
While the US’s dramatic exit from the OECD’s global tax deal naturally grabbed headlines, Trump’s premeditated move shouldn’t detract from pillar two’s lofty ambitions
The ‘big four’ firm’s audit of gambling company Entain is under the spotlight; in other news, Ireland shrugs off Trump’s rejection of pillar two
Mid-market European private equity house Inflexion, which also backs law firm DWF, has agreed to acquire a minority stake in the Dutch tax advisory firm
Donald Trump’s inauguration, pillar two, APAs and TP were all up for discussion as ITR spoke to Baker McKenzie’s two newly minted US partners
In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
Gift this article