Increase your chances of survival in battles with tax authorities

Base Erosion and Profit Shifting (BEPS)

A simplified guide to increasing your chances of survival in battles with tax authorities.

Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. In light of the Base Erosion and Profit Shifting (BEPS) Action Plan of the OECD and the many UN initiatives to set new norms for tax and transfer pricing, many tax authorities around the globe will use the grey areas in these plans to challenge as many tax structures as they can, sometimes leading to nothing more than pure aggressive behavior. As a consequence, it goes without saying that tax disputes will become a new reality in the world of companies.

Over the course of time, although a wide variety of tools have been developed (at both global as well as national levels) to address these disputes, their parallel existence has created more confusion and inconsistencies than resolving many.

Thus, during this webinar, we will address the reasons behind this flurry of tax/TP disputes and the timeline an MNE should keep in mind for mitigating such disputes. Bearing in mind that even after exploring all preventive options on the part of the MNE such as tax rulings, safe harbor principles, ISO certifications, tax disputes will still arise, leading not only to an economic penalty but, in some instances, even criminal indictment. Therefore, in this changing era of tax disputes, it becomes equally essential to be aware of and prepared for resolving such disputes in a methodical and timely manner.

Key Highlights of the webinar

  • Presentation of key tax-related areas of disputes (e.g.: withholding taxes, permanent establishment, dual residence etc.).
  • Presentation of steps involved in negotiation, mediation and court battles with tax authorities.
  • Presentation of misalignment between various global (e.g. OECD, UN, EU) tax systems with tax laws of local governments, leading to an increase in disputes.
  • Presentation of jurisprudence on dispute resolution in various countries developed from local case laws.
  • Presentation on how TPA can help relieve your burden of disputes and smoothen the process of representation before tax authorities and courts.


Prof. Dr Hans van den Hurk
International Tax and Strategy Advisor at Cygnus Tax
The Netherlands


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