Tax controversy and dispute resolution services

The tax environment is the most challenging 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. This new situation demonstrates the need for all taxpayers to:

  • adopt preventative measures (such as pre-filing rulings and enhanced relationships with certain revenue authorities);
  • ensure comprehensive documentary evidence is available to support transactions from a purpose challenge or later discovery assessment;
  • develop coordinated approaches to audits and disputes around the globe, and
  • leverage both traditional and new alternative dispute resolution techniques in order to achieve the best possible results.


{{contentList.dataService.numberHits}} {{contentList.dataService.numberHits == 1 ? 'result' : 'results'}}

How PwC can help you

Our Tax Controversy and Dispute Resolution network can help you:

  • implement consistent and defensible practices and policies
  • gain a better understanding of your risks and exposures; and
  • manage your tax disputes, audits, and examinations worldwide

In addition, we have a number of technology solutions available that can support in each of the above areas. 

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

We can help you develop sound policies and processes that can provide defensible models and help safeguard your organisation against audits and disputes. We can also support in the creation of a defence file - ensuring all evidence supporting the transaction is maintained in order to defend any audit, should it arise.

By understanding your organisation and its policies, we can help you effectively manage tax audits and examinations. Where relevant we can provide technological solutions to support in the management of tax audits.

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.

We can work with you, at both the local and international level, to reduce or eliminate prolonged disputes or the likelihood of costly litigation, and leverage our expertise in virtually all forms of tax dispute resolution.

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 in line with local or parent company GAAP. These proactive practices should provide a defensible approach and rationale, to safeguard your organisation against non-compliance penalties and other exposures.

Tax controversy life cycle

Taking proactive steps before an audit or dispute begins

Responding to audits and managing the overall process

Providing strategic solutions to resolve disputes

< Back

< Back
[+] Read More

Why PwC?

Our Tax Controversy and Dispute Resolution network includes former tax authority officials, accountants, economists, and industry sector specialists, all of whom possess in-depth knowledge and experience of individual sectors. Our aim is to help you prevent, efficiently manage, and favourably resolve tax audits and disputes.

Local knowledge and strong relationships with government officials

The successful management and resolution of audits and controversies relies heavily on having strong relationships with revenue authorities, and a thorough understanding of local processes and procedures. Our network includes individuals who are members of local specialist groups, as well as former high-ranking government tax officials who have substantial experience working on audits and disputes, both from a client and revenue-authority perspective.

Global reach and perspective

We have Tax Controversy and Dispute Resolution professionals located in all major territories. This means we can provide you with the appropriate support to help you resolve your tax audit or dispute, wherever you need it. We can offer this support on a unilateral, bilateral, or multilateral basis, depending on your needs.

Deep technical subject matter expertise

Revenue authorities are now engaged in enforcement activities across the entire tax spectrum, including direct and indirect tax, as well as other related areas. As a result, organisations should ensure that they have the support of technical specialists in the tax area in which the audit or dispute is focused. 

Technology solutions

In addition to our skills and experience we can offer a number of technological solutions to support in the prevention and management of disputes. These range from data interrogation and document management tools to predictive analytics which can analyse the likely outcome of a claim or filing position.

Follow us

Contact us

Giovanni Bracco

Global Tax Controversy and Dispute Resolution Co-Leader, PwC United Kingdom

Tel: +44 7764 235336

Hayden Scott

Global Tax Controversy and Dispute Resolution Co-Leader, PwC Australia

Tel: + 61 7 3257 8678