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Complex International Tax controversies and dispute management

International tax controversies arise when cross-border transactions, transfer pricing arrangements, permanent establishment exposure, withholding tax positions, or treaty interpretations are questioned by tax authorities. PGAS & Associates provides specialised advisory and dispute management services to help businesses navigate complex international tax disputes across assessments, audits, appeals, and treaty-based proceedings.

Our focus is on delivering certainty, defensible outcomes, and strategic resolution—while protecting value and reputation.

Why This Service Is Needed

The international tax landscape has changed significantly, with automatic exchange of information, country-by-country reporting, BEPS-driven reforms, and increasingly aggressive transfer pricing audits. Tax authorities across jurisdictions are now more coordinated and assertive, subjecting cross-border transactions to heightened scrutiny, retrospective adjustments, and overlapping tax claims.
As a result, multinational businesses often face double or multiple taxation arising from transfer pricing disputes, permanent establishment exposure, withholding tax issues, and treaty interpretation conflicts. These controversies can escalate into prolonged audits and cross-border litigation, disrupting cash flows, increasing compliance costs, and creating regulatory, reputational, and governance risks—especially where documentation or positions are inconsistent.

Key Risks and Practical Challenges

Challenges & Risks Involved

International tax disputes present unique and complex challenges. Without expert handling, such disputes can significantly erode enterprise value, strain management bandwidth, and create prolonged uncertainty. Key challenges and risks include:
  • Exposure to double or multiple taxation
  • Complex transfer pricing adjustments and benchmarking disputes
  • Permanent establishment exposure and profit attribution risks
  • Treaty interpretation conflicts between jurisdictions
  • Lengthy litigation timelines with uncertain outcomes
  • Stringent documentation and evidentiary requirements
  • Reputational, regulatory, and operational risks for management

Our Approach

At PGAS & Associates, we follow a resolution-focused and evidence-driven approach to managing international tax controversies. Our methodology is designed to address disputes comprehensively while minimising risk and uncertainty. It includes:
  • In-depth analysis of facts, transactions, and business models
  • Rigorous review of transfer pricing policies and treaty positions
  • Identification and evaluation of appropriate dispute-resolution pathways.
  • Preparation of technically robust, defensible submissions supported by strong documentation
  • Strategic coordination with legal counsel and international advisors to ensure alignment across jurisdictions
  • Proactive dispute-avoidance and risk-mitigation planning to prevent escalation

Our objective extends beyond dispute management—we aim to prevent disputes wherever possible and deliver long-term tax certainty for our clients.

Our Services

PGAS & Associates provides end-to-end advisory and dispute management support across the full lifecycle of international tax controversies. Our services are designed to deliver certainty, defensibility, and efficient resolution in high-risk cross-border tax matters.

1. International Tax Audit & Assessment Support

We assist clients during transfer pricing audits and international tax assessments by tax authorities. Our support includes transaction analysis, audit strategy, preparation of submissions, handling information requests, and representation before assessing officers and specialised TP units.

2. Transfer Pricing Dispute Management

We manage disputes arising from transfer pricing adjustments, benchmarking challenges, and profit attribution issues. Our services cover review of TP documentation, economic analysis, selection and defence of comparables, and preparation of litigation-ready transfer pricing positions.

3. Permanent Establishment (PE) & Profit Attribution Advisory

We advise on disputes involving PE exposure and attribution of profits across jurisdictions. Our approach integrates legal interpretation with functional and financial analysis to defend or quantify PE-related tax exposure.

4. Treaty Interpretation & Withholding Tax Disputes

We support disputes relating to tax treaty interpretation, characterisation of income, beneficial ownership, and withholding tax obligations. Our services include technical analysis, treaty-based arguments, and preparation of defensible positions before tax authorities and appellate forums.

5. Litigation & Appellate Support

We support clients in international tax disputes before appellate authorities, tribunals, and courts by preparing technical submissions, financial analysis, and expert reports. We work closely with legal counsel to strengthen factual and economic aspects of the case.

6. Dispute Prevention & Risk Mitigation Advisory

We assist clients in identifying high-risk transactions, strengthening documentation, aligning positions across jurisdictions, and implementing proactive strategies to reduce the likelihood of future international tax disputes.

Why PGAS & Associates

We combine technical rigour with strategic insight to protect our clients’ interests.

Deep expertise in international taxation and dispute resolution

Strong integration of tax, accounting, valuation, and forensic analysis

Independent, objective, and defensible advisory approach

Experience in high-scrutiny and high-value disputes

Practical, commercially aligned solutions—not just technical opinions

Proven capability to support matters before tax authorities, tribunals, and courts

Who We Serve

We advise and represent:
  • Multinational corporations and Indian groups with overseas operations
  • Foreign companies operating in India
  • Promoters, boards, and senior management
  • Tax and legal teams handling complex cross-border disputes
  • Businesses facing transfer pricing audits, treaty disputes, or double taxation issues

Contact Us Today

International tax disputes demand timely, expert, and strategic intervention. Contact PGAS & Associates today to manage international tax controversies with clarity, confidence, and certainty.