Tax Disputes

Sophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.

Eddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.

Luis Coronado and Matt Andrew of EY unpick the OECD’s consultation documents related to tax certainty under pillar one and find that there are many unresolved issues in terms of tax dispute resolution.