The global tax environment is changing, ushering in an era of transparency and a combined international effort against global non-taxation. We have also seen the Inland Revenue Department (IRD) adopting initiatives to counter Base Erosion Profit Shifting (BEPS) activities and taking a more conservative and stringent approach during their review in the past few years. This means that Hong Kong taxpayers are facing enormous pressure from the IRD to justify their tax filing position.
There has been unprecedented surge in tax disputes in recent years involving technical issues and/or disagreement about the facts. Some of these cases have led to tax audits or investigations, and some involve tax exposures both locally and overseas. Large or multinational taxpayers are not the only ones affected – small and medium-sized enterprise taxpayers and even tax-exempt charities are also under increased scrutiny.
To address these changes in the tax landscape, PwC Tax Controversy and Dispute Resolutions Services (TCDR) offer a wide range of services to help taxpayers navigate their way through issues that have been challenged by the IRD.
The core TCDR team includes former IRD officers with over 30 years' experiences in dispute resolution, transfer pricing experts and specialists with litigation skills. The team also collaborate with different specialist groups within the PwC global network to assist taxpayers in the resolution of cross-border tax controversial issues and disputes.
In the tax controversy cycle, TCDR team can help taxpayers prevent, manage and resolve their tax controversies and disputes.
We identify and mitigate potential tax controversy risks and exposures by:
We can conduct regular reviews of the business operations, with reference to the most up-to-date tax regulatory and practical environment, to help taxpayers manage their potential tax controversy risks and exposures:
We take a proactive approach to assist taxpayers in resolving tax disputes with IRD as soon as possible:
Prevention is always better than cure. A thorough understanding of the recent tax landscape in Hong Kong is essential for taxpayers to minimise their tax controversy risks. Our subject matter expert regularly share insights on how to prevent, manage and resolve tax controversies and disputes.