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Tax investigations and disputes across borders
Comparative guide
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Staying ahead in an era of heightened scrutiny

Tax authorities across Europe and the US are increasing their scrutiny of large businesses, and tax investigations and disputes are rising rapidly as a result. From transfer pricing and tax structuring, to executive renumeration and intra-group financing arrangements, large businesses are increasingly facing sophisticated tax audits. The stakes have never been higher—but with the right insights, you can be proactive.

Our 2025 Tax investigations and disputes across borders guide is your essential resource. It answers critical questions about tax dispute trends, tax authority powers, the tax litigation framework, and potential civil and criminal liabilities across nine jurisdictions, helping you anticipate challenges and make informed decisions with confidence.

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Blog
Mar 14 2025
The Procurement Act 2023 and Tax: What heads of tax and legal teams need to know
The Procurement Act 2023 came into force on 24 February 2025. As with the regime the Act replaces, suppliers to the UK government risk...
Blog
Jan 28 2025
Themes in UK corporate tax disputes for 2025 (and beyond)
Like climate change, while the corporate tax disputes landscape in the UK changes relatively slowly, distinct trends can be observed when...
Blog
Jan 2 2025
CJEU finds Spanish withholding tax rules applicable to non-resident loss-making investors are contrary to EU right to free movement of capital
The Court of Justice of the European Union (CJEU) has recently issued a judgment (Case C-601/23) on the entitlement of a non-resident...
Blog
Dec 19 2024
Tax investigations and disputes across borders guide 2025
We are continuing to see a significant number of large-scale tax investigations and disputes internationally, and with governments across...
Blog
Oct 31 2024
Autumn Budget 2024: delivering difficult decisions
In the first Budget delivered by the Labour Party since 2010 (and the first given by a female Chancellor since the role came into...
Blog
Sep 27 2024
Privilege in the context of European tax investigations: Court of Justice confirms tax advice is privileged
Almost all corporate taxpayers will have sought the advice of tax lawyers at one time or another – be it in the context of a transaction,...
Blog
Jun 21 2024
Workforce-related tax investigations: watch out for your workers
There are, of course, an infinite number of things that can prompt a tax investigation or audit – but within that plethora of...
Blog
May 8 2024
A Kwik decision from the Court of Appeal in the latest ‘unallowable purposes’ case
The Court of Appeal has confirmed that the loan relationship unallowable purpose rule in section 441 CTA 2009 applies to deny interest...
Blog
Apr 16 2024
Tax Indemnity Claims: Complying With the Notice Provisions in ‘Full-Recourse’ and ‘W&I-Backed’ M&A Deals
Bringing a contractual claim following the successful conclusion of an M&A transaction is sometimes unavoidable.  It is important to...
Contacts
London
Helen BuchananPartner
London
Sarah BondPartner
Paris
Cyril ValentinPartner
Paris
Vincent Daniel-MayeurPartner
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