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Risk Reshaped: Tax Disputes Outlook 2022–2025
Digitalization, economic conditions and public policy are changing the shape of taxation worldwide. With scrutiny by tax authorities increasing, multinational entities need comprehensive understanding and fresh approaches to prevent and resolve tax disputes.
With deep understanding of procedural rules and substantive issues, clients benefit from Baker McKenzie’s creative approaches to problem solving. Baker McKenzie’s Tax Disputes team includes former tax enforcement and government officials from key jurisdictions worldwide. From controlling the flow of information during audits to presenting persuasive arguments in court, appeals and alternative dispute resolution proceedings, our experienced tax litigators advise clients at all stages of disputes.
How we can help:
- Planning assistance
- Litigation analysis
- Pre-audit preparations
- Audit and collection proceedings
- Protests and appeals
- Litigation in the courts
- International tax law and procedure
- Criminal defense
- Rulings and reform advocacy
Using our deep expertise and lengthy experience, we have successfully litigated some of the largest tax disputes on record worldwide.
Recent Accolades
- Tax Litigation and Disputes Firm of the Year, EMEA Tax Awards, International Tax Review 2022
- Tax Disputes Firm of the Year in Italy, Luxembourg and Peru EMEA and Americas Tax Awards, International Tax Review 2023
- Tier 1 in Tax Controversy in Belgium, France, Indonesia, Luxembourg, Malaysia, Mexico, Peru, Poland, Spain, Türkiye, Venezuela, United Kingdom, and in the United States, California, Illinois, New York, and Texas, 2024 International Tax Review World Tax Guide
- Tier 1, US Taxes: Contentious, 2024 Legal 500 United States
- Band 1, Tax Controversy, 2024 Chambers USA
Related Insights
- IOECD publishes the long-awaited commentary to model GloBE rules while the EU struggles to reach unanimity on its implementing directive
- Risk Reshaped: Tax Disputes Outlook 2022–2025
Key Contacts
Jorge Narvaez-Hasfura Mexico City |
Antonia Azpeitia Madrid |
Arianne Calloud Paris |
George Clarke Washington, DC |
Ponti Partogi Jakarta |
Amid intensifying scrutiny by tax authorities across Asia and the Pacific Rim, Baker McKenzie helps multinational entities prevent disputes through proactive compliance, and anticipate and defend against potential audits. In the event of tax controversies, our experienced team helps you pursue the best remedies for your organization before regulators and courts.
Recent Accolades
- Tier 1 in Tax Controversy in Indonesia and Malaysia, 2023 International Tax Review World Tax Guide
Related Insights
Key Contacts
Ponti Partogi Jakarta |
Simone Bridges Sydney |
Allen Tan Singapore |
Brendan Kelly Shanghai and Beijing |
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Adeline Wong Kuala Lumpur |
Steven Sieker Hong Kong |
Fred Burke Ho Chi Minh City/Hanoi |
Panya Sittisakonsin Bangkok |
Through representation before the European Court of Justice, criminal investigations by local tax authorities, and new tax challenges, multinational entities have trusted Baker McKenzie’s European Tax Disputes Team as their counsel.
Our team provides you with broad experience and insight into the policy, laws and enforcement practices across the region. Combined with deep insight into local laws and enforcement practices, our integrated team of practitioners can help you address all multijurisdictional aspects and effects of audits or disputes, as well as anticipate and adapt to new rules.
Recent Accolades
- Tax Litigation and Disputes Firm of the Year, EMEA Tax Awards, International Tax Review 2022
- Tax Disputes Firm of the Year in Italy and Luxembourg, EMEA Tax Awards, International Tax Review 2024
- Tier 1 in Tax Controversy in Belgium, France, Luxembourg, Poland, Spain, Türkiye and United Kingdom, 2024
Related Insights
- Luxembourg: ATAD III - Between fair objectives and uncertain outcome
- Spain: The CJEU declares the Spanish regime for foreign assets that are not declared within the tax deadline to be illegal under EU Law
- UAE: Supreme Court continues its rulings in favour of tax payers, sets another landmark principle
Key Contacts
Maria Antonio Azpeitia Madrid |
Ariane Calloud Paris |
David Jamieson London |
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Eric Meier Paris |
Julia Permeke Brussels |
Michele Santocchini Rome |
Prevent tax disputes in Latin America through proactive compliance, and anticipate and defend against potential audits in the region’s 20 jurisdictions with the advice of Baker McKenzie. Our Latin America Tax Disputes Practice provides you with broad experience and insight into the laws and enforcement practices across the region. Combined with deep insight into local laws and enforcement practices, our integrated team of practitioners can help you address all multijurisdictional aspects and effects of audits or disputes, as well as anticipate and adapt to new rules affecting your existing structures in Latin America.
Recent Accolades
- Tier 1 in Tax Controversy in Mexico, Peru and Venezuela, 2024 International Tax Review World Tax Guide
Related Insights
- Venezuela: Large Financial Transactions Tax Law amended; exoneration along with non-taxable assumptions on certain transactions
- Mexico: Beneficial owner records - New obligation for all legal entities and vehicles
Key Contacts
Martin Barreiro Argentina |
Luis Adrian Jimenez Robles Mexico |
Alberto Maturana Chile |
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Ciro Meza Colombia |
Rolando Ramirez-Gaston Peru |
Navigate and resolve audits with the Internal Revenue Service, Canadian Revenue Authority, state tax authorities and those worldwide with Baker McKenzie’s North American Tax Disputes Practice. The team has advised clients on managing and mitigating risk in the United States, Canada, Mexico and at state and local levels for more than 40 years.
Trusted tax counsel for many of the highest profile tax cases on record, we are well-regarded for litigation and the appeals process. For jurisdictions across North America, clients have turned to Baker McKenzie to advise on:
- Managing and mitigating risk, identifying the issues most likely to face IRS and CRA scrutiny, and mitigating risk through strong, contemporaneous support and comprehensive strategies for bringing issues to successful resolution.
- Navigating IRS and CRA audits, including tax authority information requests and how to manage the audit process.
- Resolving disputes with the tax authorities, advocating for and helping clients to navigate and identify the best administrative dispute resolution mechanisms available to you, including IRS Appeals, the MAP process, Advance Pricing Agreements or other options.
Recent Accolades
- Tier 1 in Tax Controversy in Mexico, and in the United States (including Illinois, New York, and Texas), 2024 International Tax Review World Tax Guide
- Tier 1, US Taxes: Contentious, 2024 Legal 500 United States
- Band 1, Tax Controversy, 2024 Chambers USA
Related Insights
- United States: The IRS shifts its gaze to Section 41 refund claims
- United States: OECD Pillar Two and changes to GILTI - Good for Corporate America?
- United States: Second Circuit upholds District Court’s dismissal of lawsuit challenging USD 10,000 cap on state and local tax deduction
Key Contacts
George Clarke Washington, DC |
Summer Austin Washington, DC |
Scott Frewing Palo Alto |
Drew Crousore Palo Alto |
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Bobby Albaral Dallas/Houston |
Joy Williamson Dallas/Houston |
Mark Oates Chicago |
Dan Rosen New York |
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Mark Roche San Francisco |
Jorge Narvaez-Hasfura Mexico City |
Jacques Bernier Toronto |