Greater tax transparency and fiscal pressure on governments have resulted in greater volatility in the global tax landscape.  This gives rise to an increasing number of legal disputes between taxpayers and tax authorities practically in every tax jurisdiction. The risk of legal proceedings has become prevalent as a result of intensified cross-border audits.  Companies operating internationally need a new way of dealing with tax controversies.

Tax controversy is an integral part of our comprehensive service offering. Our team at Taxise Asia LLC (“WTS Taxise”) includes former members of the legal team at the tax administration, the Income Tax Board of Review and International Association of Tax Judges. We assist taxpayers during tax audits and represent them in negotiations with the tax authorities, whenever possible, and before the various national tax tribunals and courts, including hearings with judges and oral submission of the defence before administrative and judicial courts.

Given our expertise in all aspects of tax law, our tax controversy team can offer a unique combination of in-depth knowledge of both administrative practices of tax authorities and formal tax law. Our team handles all tax related disputes (corporate tax, international tax (MAP), indirect tax, personal income tax, customs and excise duty, stamp duty, etc.).

Our integrated approach starts long before actual legal proceedings take place with pre-audit consulting to help identify risks and devise defence strategies. We are able to assist with pre-audit consulting on a cost effective basis especially where we also assist clients with their tax compliance obligations. We can represent taxpayers during litigation, dispute resolution and the Competent Authority negotiations, including expert testimony in specialised areas such as transfer pricing. Thereafter, our ability to assist in post-agreement tax return amendments and ongoing annual compliance completes our end-to-end service offering.

Our services in Local and Cross-border Tax Controversy include:

• Pre-audit Consulting
• Audit Management
• Dispute Resolution Representation
• Mutual Assistance Procedures (MAP) and Advanced Pricing Agreement (APA) negotiations
• Cross-Border Dispute Resolution Strategy
• Litigation Representation and Expert Witness Testimony

As part of WTS Global’s Tax Controversy Service Line, our specialists at WTS Taxise collaborate with WTS tax and legal experts from more than 100 countries, enabling them to provide client advice drawn from best practices and extensive experience in handling audits and tax-related litigation. This translates into better results for your tax controversy case and in a manner which is consistent with a globally aligned tax controversy strategy.