Tax Litigation & Mediation Which tax information is shared with tax authorities?

A fully in control tax position in publicly quote companies will have to be disclosed to the shareholders, i.e. if a tax risk is recognized where the ‘income reported by the MNE’ differs from the ‘income accepted by the tax authorities’ is reported as so called ‘uncertain tax postions’ (UTPs). The variety of sources used by tax authorities is without limitations, e.g. information obtained through banks, ISP, insurance companies, advisors, other tax authorities (through an extensive exchange of tax data treaty network) and other public and closed databases. Some tax authorities like the Chinese SAT are already moving to big data analytics to speed up the process of assessing the quality and accuracy of information provided by the tax payer versus the information obtained through multiple other sources. The same approach is taken by tax authorities to private individuals as well as privately held companies.

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