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I think that there are really very specific trends that one can highlight when thinking about the past five years.
We are seeing really the same trends developing in each country.
The trends in tax dispute resolution in Australia are two fold. One there’s a focus on engagement with the tax office and the other one is about alternative dispute resolution.
There is an increasing trend and possibly not only in Spain, also in dispute prevention mechanism like APA.
Basically the dollars are getting larger and larger and larger. Certainly in Canada we’ve seen several assessments over a billion dollars.
We are seeing more disputes and we’re seeing more disputes going to court.
We are seeing revenue authorities looking for revenue. Which means more aggressive examinations or inquiry or investigation depending on what it’s called in that particular country.
Transfer pricing is one of the main areas where the international element of tax controversy pops up. Because typically tax authorities on both sides of the border will want tax certain profit.
The largest trend these days is certainly the explosion in transfer pricing. That is an area that affects every single country, every revenue authority is focused on transfer pricing, even for small companies.
If you think back about ten years ago possible borders protected tax payers. Therefore if not in your own jurisdiction somehow it did not exist, now this is not the case at all. Tax authorities work closer together in exchange of information and also in tools that we are going to see them as powerful tools, possibly in the very near future
Today you see a development where the focus is more on having honest (?) relationships with tax authorities, particularly in the European countries. Where you try to avoid ending up in litigation by discussing certain matters up front.
Information sharing is a real issue in Australia both on a local level and a global level
In addition, what we’re seeing is a kind of proliferation of revenue authorities becoming almost like a global revenue authority where there is much more information sharing. There is much more effort to work together and make sure that each country that’s affected gets the right answer for their country.
At a higher level we see a lot of issues that are discussed at for example at the OECD level.
The focus of the OCD is very much on first exchanging information between tax authorities, but also actually doing the audits together.
We see them talking about trying audits throughout jurisdiction. So there is certainly a lot in play and certainly lot of take aways from these international fora(?) which they attend.
In working with our clients the biggest need I see is simply an understanding of the process and taking away. A lot of the questions they have about what is going on the other side, how long it’ll take, where to go to get the right results or the results that they want.
What KPMG offers clients is a whole firm (?) approach to dispute management and resolution.
The way in that we help our clients with these global issues. Is really by offering a coordinated approach and a number of experts in each country with specific expertise in both the technical issue as well as the process in working through that issue in their country.
KPMG, I think is widely recognized for its technical skills of the advisors and expertise is very appreciated.
A number of our partners have experience having worked for the revenue authorities.
I think having ex government professionals certainly differentiator. Sometimes if you come from the government you speak the same language or you are able to remember how to speak that language and it just makes it easier to get the case closed.
The first thing you need to take into consideration is honestly, honestly for me is one of the most important values. Together with efficiency and that means being, or have a very good knowledge of country specificities as well as the global tools that are in our hands.
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