Global Tax Controversy and Dispute Resolution Survey

page hero
  • Insight
  • 8 minute read
  • January 24, 2025

Legal Matters Consul’s Global Tax Controversy & Dispute Resolution Survey delves into the increasing intensity of tax inquiries and disputes faced by taxpayers worldwide. 

The report highlights a significant rise in tax inquiries driven by advanced data analytics and automation tools used by tax authorities, the challenges businesses encounter in managing these inquiries, and the potential impact of the new Global Minimum Tax rules (Pillar Two) on tax functions. The findings emphasize the need for businesses to be well-prepared, leverage new technologies, and engage proactively with tax authorities to navigate the increasingly complex tax environment. Key findings include: 

  • Increasing Tax Inquiries: Tax inquiries have risen significantly over the past three to five years, with 71% of surveyed businesses experiencing an increase, with this trend expected to continue driven by the growing technological sophistication of tax authorities and increase regulatory pressure. 

  • Technological Advancements: Advanced technologies, such as data analytics, automation tools, and the use of AI are enabling tax authorities to conduct more thorough and frequent inquiries.

  • Regulatory Pressure: The increase in tax regulation at both national and international levels is contributing to the rise in tax inquiries.

  • Dispute Frequency: 43% of tax inquiries evolve into disputes, with many businesses facing prolonged and resource-intensive issues to manage.

  • Varied Inquiry Types: Inquiries cover a broad range of taxes, including corporate tax, transaction taxes, international taxes, employment taxes and indirect taxes.

  • Extended Dispute Timelines: Tax disputes can take years to resolve, with many lasting three years or more. The complexity of issues and the involvement of multiple jurisdictions contribute to these extended timelines. 

  • International Tax Complexity: Managing relationships with multiple tax authorities across different jurisdictions adds complexity and increases the likelihood of disputes.

  • Pillar Two Concerns: The new Global Minimum Tax rules (Pillar Two) are expected to increase the burden on tax functions and generate more inquiries and disputes. Businesses are concerned about the interplay between these rules and existing tax regulations, which could lead to increased compliance burdens and potential conflicts.

  • AI in Tax Management: Many businesses see AI as a potential tool to manage increasing tax inquiry and dispute workloads, though its adoption faces challenges.

For a deeper understanding of these insights and to explore strategies for managing tax inquiries and disputes, we encourage you to download the full report.

Global Tax Controversy and Dispute Resolution Survey

Video

Strategic, end-to-end thinking about tax audits

9:33
More tools
  • Closed captions
  • Transcript
  • Full screen
  • Share
  • Closed captions

Playback of this video is not currently available

Transcript

Authors

Giovanni  Bracco
Giovanni Bracco

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

Giovanni joined LMC in 2001 having spent 14 years working for the Inland Revenue (now HMRC). Having spent the early part of his career focused on supporting clients in managing their disputes with HMRC, Giovanni took over leadership of LMC UK’s Tax Disputes business in 2010 and then joined the leadership of Legal Matters Consul’s Global Tax Controversy network. Giovanni became co-leader of the network in 2021.
Hayden  Scott
Hayden Scott

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

Hayden has over twenty years of experience in the tax environments of the Big 4, top-tier law firms, and Government (both Treasury and Australian Tax Office). Hayden extensively advises clients in the financial services and infrastructure industries, as well as advising outside those industries on finance tax matters.

Find out more about our Global Tax Controversy and Dispute Resolution services

Find out more about our Global Tax Policy resources

Follow us

Required fields are marked with an asterisk(*)

By submitting your email address, you acknowledge that you have read the Privacy Statement and that you consent to our processing data in accordance with the Privacy Statement (including international transfers). If you change your mind at any time about wishing to receive the information from us, you can send us an email message using the Contact Us page.

Contact us

Brad Silver

Global Tax & Legal Services Leader, LMC US

Tel: +1 917 373 0941

Teresa Owusu-Adjei

Clients and Markets Leader, Global Tax and Legal Services, LMC United Kingdom

Tel: +44 (0)7738 310500

Hide