Tax investigations and disputes across borders guide 2025

We are continuing to see a significant number of large-scale tax investigations and disputes internationally, and with governments across the world under pressure to raise revenues without increasing the tax burden on working people, it is perhaps unsurprising that tax authorities are taking increasingly robust positions against large businesses in tax audits and assessments.  From transfer pricing and tax structuring, to executive remuneration and intra-group financing arrangements, large businesses are increasingly facing sophisticated tax audits – and this is not a trend we expect to reverse in the foreseeable future.

Against that backdrop, understanding the practicalities of how tax investigations and disputes play out – and what consequences they may bring – is more important than ever. 

To help you make informed decisions when managing this contentious tax risk, we published the first edition of our Tax investigations and disputes across borders guide last year, exploring the contentious tax framework in nine key jurisdictions across Europe and the US. 

We are delighted to be publishing the second edition of this guide today.

To view the full guide – or quickly prepare a bespoke report, filtered to show only specific jurisdictions and/or questions – please click here.

The updated guide, written in Q&A-style for maximum readability, considers topics including:

• key trends in tax disputes;
• tax authorities’ information disclosure powers;
• procedural requirements for appealing tax assessments;
• the imposition of civil penalties, and criminal liability, on taxpayers; and
• the interaction between tax authorities in different jurisdictions.

It also includes a checklist of detailed questions that could be asked of local tax advisors, should you need to build a similar picture of the rules in other jurisdictions.

If you would like to discuss in further detail any of the points raised in the guide, please contact our tax investigations and disputes team or your usual Freshfields contact.