Tax Controversy and Dispute Resolution

Multinational corporations are facing the most challenging tax environment in history: a convergence of global forces has resulted in a substantial increase in the number and size of tax audits, assessments, and disputes with revenue authorities worldwide.

Switzerland has long standing history and tradition to address tax issues on a proactive basis by means of so called "ruling requests" with the respective tax authorities in charge. Nevertheless, tax disputes emerge on a local Swiss level in all areas of direct and indirect taxation. But particularly also on an international level, affiliates of Swiss parent companies face a challenging tax audit environment all over the world and are exposed to tax adjustments which may result to a double tax exposure. PwC's aim is to help you proactively prevent, efficiently mange and favourably resolve such tax audits and disputes.

Our Tax Controversy and Dispute Resolution services are delivered in five key areas:

• Tax dispute prevention techniques
  We can help you develop sound policies and processes that can provide defensible models and help safeguard your organisation against audits and disputes.
• Tax audit management practices
  By understanding your organisation and its policies, we can help you effectively manage tax audits and examinations.
• Tax dispute resolution alternatives
  We can work with you, at both the local and international level, to implement practices that can reduce or eliminate prolonged disputes – or the likelihood of costly litigation, and leverage our expertise in virtually all forms of tax dispute resolution.
• Global strategic planning of tax audits and disputes
  We can help you develop global tax dispute resolution strategies that are consistent with your goals, and utilise a wide variety of key tax approaches. We can also help you develop strategies for establishing consistent tax positions and methods worldwide, and across a variety of tax technical areas.
• Tax risk management, analysis, and disclosure
  We can analyse your various tax positions that may require financial statement disclosures, and help you develop sound policies and practices, including appropriate documentation and disclosure approaches. These proactive practices should provide a defensible approach and rationale, to safeguard your organisation against non-compliance penalties and other exposures.