Can thinking big keep your tax controversy small?

5 minute read 2 Mar 2020

Increased global interconnectivity means that tax controversy can spread rapidly among countries. 

Governments are collecting more information than ever before and are using enhanced data analysis to identify and act on tax issues. Governments are also sharing this information at a record-setting pace.

“Governments are sharing information, and tax authorities are collaborating across the border,” says Calafia Franco, EY Latin American Business Center Controversy Leader. “Now that tax authorities have more information, they are getting more aggressive. They have better position to challenge some tax issues.”

Says Jeffrey Michalak, EY Global International Tax and Transaction Services Co-Leader, “Historically, global companies treated audits as discrete events. They would settle an audit issue, a cross-border issue, with one or perhaps both sides of a cross-border transaction. That audit issue may come up in a very similar transaction somewhere around the globe, and that also would be a discrete settlement.”

“Today, with information sharing,” Jeffrey says, “when I settle the one audit, the first audit, other countries around the world where I am doing similar types of transactions in my business see that audit settlement. That influences the conversations I have with other governments around the world.”

Adds Rob Hanson, EY Global Tax Controversy Leader, “We have developed frameworks for companies to track and manage controversy globally. We’ve helped them develop globally integrated structures and policies around managing tax controversy.”

“The result,” Rob says, “is that these companies now have centralized repositories of audits. This allows them to have better oversight and control of their audits around the globe. It also allows them to share issues and best practices internally.”

Watch more in our video series on the future of tax.


Global tax controversy is surging in volume and intensity as governments collect and share more information than ever before. 

About this article