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1、Tax investigations and disputes across bordersStaying ahead in an era of heightened tax scrutinyDECEMBER 2024TAX INVESTIGATIONS AND DISPUTES ACROSS BORDERSTax investigations are on the rise and the stakes are higher than ever.Authorities across Europe and the US are ramping up scrutiny,making it ess

2、ential to be informed and prepared.Welcome to the 2025 edition of our guide to tax investigations and disputes across borders.This guide provides insights into the contentious tax landscape across Europe and the US,helping you to anticipate challenges,understand risks and respond confidently.Right n

3、ow,large-scale tax investigations and disputes are on the rise,driven by governments need to boost their revenue without increasing the tax burden on working people.As a result,tax authorities are adopting increasingly robust positions in tax audits and assessments involving large corporates a trend

4、 that we expect to continue.Sophisticated audits around transfer pricing and tax structuring are becoming more frequent,and there is heightened scrutiny of intra-group financing arrangements,executive renumeration and M&A transactions.The growing volume of taxpayer information being shared internati

5、onally means a greater risk of spillover disputes,while settlements are increasingly difficult to achieve as tax authorities become more litigious.In this context,understanding the practicalities of how tax investigations and disputes play out and what consequences they may bring is more important t

6、han ever.Businesses are increasingly recognising this as a core element of their strategic decision-making.In this guide,we answer key questions about the contentious tax framework in nine jurisdictions across Europe and the US.These questions cover topics ranging from tax authority powers to potent