Stepping out of the tax controversies bubble, it is clear that the world remains an uncertain and challenging place. Innovation and digitalisation drives many businesses, albeit often with fear and distrust of what this may mean for different groups and whether the world (or any particular country) will be a better or fairer place as a result. Likewise, trade disputes, economic protectionism and Brexit have kept more ‘normal’ tax stories (or offshore leaks) off the front pages. For many organisations and tax professionals, therefore, it is these challenges (and US tax reform) that have and will receive most attention. However, our experience and the contributions in the chapters that follow suggest that not only will the attention paid to these issues mean that challenges with resolving tax controversies as quickly and cost-effectively as possible remain unaddressed but also that these challenges will themselves lead to great tax-related controversy, not least as businesses adapt and restructure to survive in a changing world. Four main themes stand out: lack of certainty; digitalisation and transparency; internationalisation of disputes; and raised expectations.
Reproduced with permission from Law Business Research Ltd. This article was first published in Getting the Deal Through – Tax Controversy 2019 (Published: September 2018). For further information please visit www.gettingthedealthrough.com.