Tax controversy and dispute resolution

Tax & Vat Alert

We provide a wealth of publications by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally. Through analysis and comment on new law and judicial decisions of interest, they assist business executives...

SA Budget 2012

Across the world, there is impatience at the slow pace and poor outcomes of international cooperation, and there is anger about the impact of financial and governance failures on ordinary people, on employment and on livelihoods. But anger is not enough – we have...

Paying Taxes 2013

Paying Taxes 2013 is a unique study from PwC, World Bank and IFC which looks at the world's tax systems from the business perspective, providing an ability to compare tax regimes in 185 economies using a case study company...

ED Practices and remuneration trends report 2012

As the global economy has shown signs of market recovery but not at the pace anticipated, we are finding companies are once again investing in recruiting and retaining talent in an effort to align people strategy with...

AfriTax News

Welcome to AfriTax, our quarterly newsletter which provides you with a snapshot of the most significant recent tax changes on the African continent. For more detail on the relevant changes, go to the link containing a detailed document summarising the changes...

Non-Executive Directors Report

Welcome to our sixth edition of the annual review of the practices and fees trends of non-executive directors in South Africa. For the first time, this publication looks at the risk landscape facing...

Tax Law Review

The introduction of the TAA (Tax Administration Act) is primarily intended to incorporate into one piece of legislation certain generic administrative provisions which are currently duplicated in various Tax Acts. Whilst this is a eaningful result in itself...

HR Quarterly

A monthly journal published by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally. Through analysis and comment on new law and judicial decisions of interest, it assists business executives to identify developments and trends in tax law...

Tax Synopsis

A monthly journal published by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally....

Multinational corporations (MNCs) are facing the most challenging tax environment in history: a convergence of global forces has resulted in a substantial increase in the number and size of tax audits, assessments, and disputes with revenue authorities worldwide.

Fiscal demands on developed and emerging countries have placed considerable pressure on governments to raise revenue and prevent the erosion of their tax bases. Governments worldwide are cooperating as never before to share taxpayer and industry information, assist other countries with document and information requests, and participate in separate multi-country audits (including “simultaneous” examinations). Some countries are even considering the concept of "joint audits" where a single audit team--comprised of government tax inspectors and auditors from two or more countries--examines a specific taxpayer. At the same time, MNCs are experiencing increasingly complex regulations, heavy penalties, and transparency and disclosure issues.

These global forces have created an unprecedented surge in audits and disputes. Virtually no area of tax enforcement has escaped this phenomenon, which includes direct taxes (domestic and international) and indirect taxes (e.g., VAT and GST), as well as specialist areas such as customs, tax fraud, and white collar tax issues. This new situation places a premium on audit and dispute prevention techniques because MNCs are under constant competitive pressure to structure their worldwide business operations effectively and efficiently. MNCs need to develop coordinated approaches to audits and disputes around the globe, adopt preventative measures (such as pre-filing rulings and enhanced relationships with certain revenue authorities), and leverage both traditional and new alternative dispute resolution techniques in order to achieve the best possible results.

PwC’s Tax Controversy and Dispute Resolution network assists taxpayers in this emerging area. We can work with you to prevent, efficiently manage, and favourably resolve tax audits and disputes throughout the world. PwC has tax specialists to assist clients in virtually every area of dispute. We combine deep technical understanding, local knowledge, strong relationships with government officials, tax litigation experience, and a global perspective to provide you with unrivalled service.

How PwC can help you

Our Tax Controversy and Dispute Resolution network can help you manage your tax disputes, controversies, audits, and examinations around the globe. We can assist you in:

  • Tax dispute prevention techniques
  • Tax audit management practices
  • Tax dispute resolution alternatives
  • Global strategic planning of tax audits and disputes
  • Tax risk management, analysis and disclosure

The tax controversy life cycle

The life cycle of a tax controversy varies from country to country. We have successfully assisted clients in each phase of the tax controversy life cycle:

  • Pre-audit prevention phase
  • Audit / examination phase
  • Post-audit settlement / resolution phase