Tax controversy survey: Procedures and issues for selected countries

Tax controversy lawyers with Norton Rose Fulbright around the globe have prepared a sixth annual survey of certain tax controversy procedures and issues referenced below for Australia, Brazil, Canada, France, Germany, Luxembourg, The Netherlands, South Africa, the United Kingdom, and the United States.

While each tax controversy will involve unique circumstances, this survey serves as a reference tool for tax executives at multinational companies. It will be an evolving tool, and we plan to add additional countries in future surveys. If you would like additional information, please feel free to contact any of the lawyers listed on the back of this survey.

Included with this edition is a special report, on implementation of arbitration and alternative dispute resolution mechanisms to deal with intra-European Economic Community cross-border disputes.

This edition covers the following procedures and issues:

• Examinations
• Collection of information
• Dispute resolution - administrative
• Transfer pricing
• Civil and criminal penalties
• Judicial challenges
• Privilege protection for information
• Statutes of limitations
• Interest
• Reconciliation of laws/application of doctrines
• Special report: Resolving EU international tax disputes – A new way forward?

Download the report.