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Tax Controversy

Assert your rights, be proven right

A tax environment that is changing fundamentally creates big challenges, especially for international companies. Base erosion and tax transparency are keywords here. The growing complexity of legal regulations is having the inevitable effect: tax audits are taking longer, as are appeals proceedings.

PwC’s team of specialists is there for you to argue your legal case convincingly – also in international contexts – and to counter even the slightest suspicion of flaws in your tax reporting.

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Tax litigation

“Prevention is the best defence.” In line with this principle, the tax experts at PwC provide advance support in relation to reporting to tax administrations, in particular preventative disclosures in tax returns, or in the context of tax audits. This helps prevent any risks under tax criminal law. Through prudent voluntary disclosures or skilled defence in tax criminal proceedings, we get you back on dry land.

Beyond tax criminal law matters, we also provide support on tax reporting of all kinds and stand in direct contact with the authorities, using our specialist knowledge and the right negotiation strategy to optimise your tax situation. And if an appeal can’t be avoided? We will submit the appeal and represent you before all tax authorities, administrative courts such as the Austrian Federal Tax Court (BFG), as well as the Supreme Administrative Court (VwGH).

Tax controversy network

Due to the economic crisis, the pressure to maximise tax revenues and combat aggressive tax planning has intensified globally. National tax administrations are working together more closely than ever before. Joint audits with the cooperation of multiple states are the likely next step.

Considering these developments, you require a strong team of advisors, who can work together with tax administrations in international contexts and find solutions that work for all those involved. We have the expertise and provide support together with the relevant tax experts when implementing advance pricing agreements (APA) and mutual agreement procedures.

We can draw on the global support of experts from PwC’s Tax Controversy and Dispute Resolution group, which offers our clients a unique combination of technical expertise, specific knowledge of local regulations, and a global perspective.

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Thomas Strobach

Thomas Strobach

Partner, PwC Austria

Tel: +43 1 501 88-3640