International tax disputes: A growing challenge for multinational businesses
International tax disputes arise when two or more countries interpret the same income, profits, or transaction differently. This can result in double taxation, lengthy discussions with tax authorities, and significant financial uncertainty for businesses.
The increasing exchange of information between tax authorities, enhanced audit techniques, and international initiatives such as BEPS have made cross-border tax issues more likely to result in discussions or disputes. As a result, organizations should identify potential risks at an early stage and develop a clear strategy for preventing and resolving international tax disputes.
Our specialists support multinational businesses in complex international tax proceedings and help them resolve disputes efficiently and sustainably.
Resolving double taxation through MAP and arbitration procedures
When double taxation occurs, businesses can often rely on a Mutual Agreement Procedure (MAP) or an arbitration procedure. These mechanisms enable tax authorities to work together to resolve disputes arising from differing interpretations or applications of tax treaties.
A successful approach requires more than technical tax knowledge alone. International disputes demand a thorough analysis of the facts and supporting documentation, a consistent tax position across multiple jurisdictions, and effective coordination with tax authorities in different countries.
Meijburg & Co supports clients throughout the entire process, from the initial risk assessment and filing of requests to representation during negotiations between tax authorities. Through our collaboration within the global KPMG network, we combine international expertise with local insight to effectively manage cross-border tax disputes.
Why choose Meijburg & Co for international tax disputes?
International tax disputes frequently involve multiple countries, different types of taxes, and a variety of legal procedures. Successfully managing these matters requires an integrated approach that brings together tax, legal, and strategic considerations.
Our Tax Controversy & Litigation specialists combine in-depth knowledge of international tax treaties with extensive experience in MAP proceedings, arbitration procedures, and disputes with tax authorities around the world. We not only help clients resolve existing disputes, but also advise on tax governance, documentation, and risk management to help prevent future conflicts.
By identifying issues early, selecting the most appropriate procedure, and coordinating matters across jurisdictions, we help organizations reduce uncertainty, avoid double taxation, and achieve sustainable outcomes.
Early action makes a difference in international tax disputes
A clear strategy, consistent documentation, and the right procedural approach can significantly increase the likelihood of an efficient resolution.
Our Tax Controversy & Litigation specialists are happy to discuss the most effective approach for your organization.
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Tax Controversy & Litigation
Tax disputes and litigation
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Transfer Pricing
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FAQ
What factors contribute to a successful approach to an international tax dispute?
A successful approach requires a combination of tax expertise, procedural experience, and effective coordination across multiple jurisdictions. Early analysis of the facts, consistent documentation, and a well-defined dispute strategy are essential to achieving a favourable outcome.
What does the increasing international cooperation between tax authorities mean for multinationals?
The growing exchange of information between tax authorities is leading to greater scrutiny of cross-border transactions, transfer pricing arrangements, and potential instances of double taxation. As a result, multinational businesses are facing an increasingly complex and transparent tax environment.
How can organisations prepare for increased scrutiny from tax authorities?
Strong tax governance, consistent documentation, and a proactive dispute strategy can help organisations manage tax risks and respond effectively to tax audits and enquiries. Taking preventive measures early can significantly improve an organisation’s position in the event of a dispute.