Tax Controversy and 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.

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.

Our Services

We have successfully assisted clients in each phase of the tax controversy life cycle:

Pre-audit prevention phase

We can work with you during the pre-audit prevention phase to achieve successful results by:

  • reviewing your transfer pricing policies;
  • reviewing your transfer pricing or VAT supporting documentation;
  • submitting Advance Pricing Agreements;
  • reviewing your operational model and processes;
  • coordinating "course of conduct" reviews to ensure that post-structuring operations align with initial implementation plans;
  • assisting in transactional due-diligence to identify tax audit and controversy risks and exposures;
  • carrying on pre-audits to identify transfer pricing and tax audit impacts;
  • once risks are identified, develop and implement other option to the current business model to mitigate your company's risk profile;
  • training your company personnel.
Audit/examination phase

We can help you in managing and responding to investigations, audits, and examinations initiated by tax authorities worldwide in order to resolve disputes efficiently and favourably. This notably includes:

  • routine and complex audit management related to information requests,
  • support in document production,
  • assistance in discussions with the tax authorities.
Post-audit settlement/resolution phase

If your tax dispute is not resolved, we can provide you with a full range of dispute resolution options, including:

  • submission of pre-litigation claims with the tax authorities;
  • preparation of litigation support for court proceedings;
  • assistance in mediation;
  • Advance Pricing Agreement negotiations using "roll-back" features to resolve pre-existing disputes;
  • check of opportunity to use Competent Authority and Mutual Agreement Proceedings to resolve international tax disputes, i.e. cases of double taxation, as well as inconsistencies in the interpretation and application of a double tax treaty and assistance to negotiations in these proceedings.

Contact us

Begga Sigurdardottir

Tax Partner, PwC Luxembourg

Tel: +352 49 48 48 3194

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