International tax dispute resolution: key items to consider when determining strategy and forum

A webinar presented by the IBA Taxes Committee, supported by the IBA Corporate Counsel Forum, the IBA Litigation Committee and the IBA Arbitration Committee

This webinar will discuss key procedural aspects, as well as the pros and cons, of different dispute resolution mechanisms, with particular emphasis on the interaction between international (in particular, MAP and arbitration) and domestic mechanisms and the important – and often difficult – choices taxpayers must make. It will address subjects that should be considered for determining dispute strategy and fundamental choices on forum such as taxpayer procedural rights and protections, the availability and use of international and domestic law remedies and admissibility limitations and risks, pursuing MAP first or domestic litigation first strategies and the recent Oracle case dealing with fundamental taxpayer rights regarding a MAP first strategy, timing considerations and concerns, and the tactical benefits and risks of available procedures. These subjects will be addressed from different perspectives and in the context of different kinds of disputes, such as business restructurings/exit taxes, cost plus challenges, divergent TP practices and withholding tax cases.

The webinar aims to bring together tax practitioners, government officials and in-house counsel from across jurisdictions, combining legal perspectives from private practice with insights from those working within organisations and government.

As we are limited to 1,000 registrants, we request that you please only register for this event if you will be attending.