Tax authorities worldwide are under increasing pressure to generate revenue, causing a rise in tax audit activity across all taxing jurisdictions and all types of tax. Particular uncertainty can arise as global businesses seek to access new and developing markets where the local tax environment may be unfamiliar and extremely unpredictable.

This pressure on tax authorities is resulting in more investigation, larger adjustments, and increased potential for penalties and interest. Wherever you do business, it’s important to approach your tax matters proactively and be ready to respond if and when a local tax investigation begins. KPMG’s Dispute Resolution & Controversy professionals can help you prepare to manage any tax authority challenge that comes your way.

For any business or person preparing for or facing a tax audit, appropriate strategies for response and compliance are critical. Without a plan of action for resolving potential tax disputes, uncertainty, inefficiency and lost opportunities can result.

When your organization finds itself under the tax collector’s microscope, will you be ready to take control and manage the tax controversy and resolution process toward its best possible end?

• What protocols do you have in place to actively manage and address tax risk to avoid future tax disputes and exposures?
• Have you proactively and thoroughly documented your uncertain tax positions and your tax transactions, including cross-border transfer prices?
• Are your analyses of your tax positions well stated, complete and supported by relevant documentation?
• Do you have a process in place for retaining confidential tax analyses under the protection of legal privilege in all relevant jurisdictions where a form of this protection is available?
• Have you formulated a broad-ranging strategy for engaging with the tax authorities in order to resolve disputed or controversial tax issues?
• Do you have a clear picture of possible resolution scenarios, whether by negotiated resolution or, in some jurisdictions and if necessary, litigation* of disputed tax issues?
• Do you know your options for dealing with a number of open enquiries strategically rather than on a piecemeal basis? 
• Are you engaging with the tax authorities in the most effective way?
• Have you considered the impact of your resolution on your tax positions in all affected jurisdictions?

KPMG’s Dispute Resolution & Controversy network helps companies and, in some countries, high net worth individuals, protect against, prepare for, and respond to challenges by the various tax authorities. Our worldwide network of professionals, many former revenue authority officials and attorneys, is experienced in all stages of the tax dispute continuum – from pre-transaction analysis and documentation to closing the file on items in dispute. Teaming with your KPMG Tax Team or your in-house tax professionals, we work to help lessen the likelihood of a challenge or audit before a dispute arises and to resolve those matters that ultimately become the subject of a dispute. Our practical, effective approach focuses on determining that your tax positions are documented in a way that helps to mitigate audit risk. Should a dispute arise, we strive to secure a favorable outcome.

Whether your tax issues involve income taxes, transfer pricing, indirect taxes or other taxes, KPMG’s Dispute Resolution & Controversy Services can help. Our network of professionals has a deep understanding, based on practical experience, of how best to approach resolution of large, complex tax disputes, including multijurisdictional issues.

KPMG can assist in achieving certainty on disputed tax issues quickly and efficiently and in a way that can help build an effective and respectful relationship with the tax authorities.