Tax Controversy and Dispute Resolution

Tax Dispute Resolution


While taxpayers are under constant competitive pressure to structure their operations efficiently, fiscal demands on developed and emerging countries have placed considerable pressure on governments to raise revenue and prevent the erosion of their tax bases. Government worldwide are cooperating as never before to share taxpayer and industry information, assist other countries with document and information requests, and participate in separate multi-country audits. This convergence of global forces has resulted in a substantial increase in the number and depth of audits, assessments and disputes with fiscal authorities worldwide, who are engaged in enforcement activities across the entire tax spectrum including:

Our Tax Controversy and Dispute Resolution team assists taxpayers facing this challenging tax environment. The diversified experience of our experts is combined to help our clients preventing, efficiently managing and favourably resolving tax audits and disputes. Integrated in a worldwide network, our specialists not only focus on the Luxembourg aspects, but also integrate cross-border risks and impacts, deriving for example from:

  • Claims of dual residency / permanent establishment
  • Conflicts of qualification under a treaty
  • Exit charge claim in relation to a transfer of functions to Luxembourg


Luxembourg has a long standing history and tradition to address tax matters on a proactive basis by means of the so called Advance Tax Agreement with the Luxembourg tax authorities. Nevertheless, tax disputes emerge on a local and international level in all areas of direct and indirect taxation where affiliates of Luxembourg parented companies face a challenging tax audit environment and are exposed to tax adjustments which may result to a double taxation.

How PwC Luxembourg can help you

PwC luxembourg's aim is to help you proactively prevent, efficiently manage and favourably resolve such tax audits and disputes. PwC Luxembourg has tax specialists to assist clients in all the areas of dispute. We combine deep technical understanding, local knowledge, tax litigation experience, and a global perspective to provide you with unrivalled service.