PwC’s Tax Controversy and Dispute Resolution Survey

The report of the 2025 global survey discusses a notable increase in tax inquiries due to the use of advanced data analytics and automation tools by tax authorities, the challenges businesses face in handling these inquiries, and the potential effects of the Global Minimum Tax rules (Pillar Two) on tax functions.

It stresses the importance for businesses to be prepared, use new technologies, and engage with tax authorities to manage the complex tax landscape.

Key findings include:

• A significant rise in tax inquiries over the past three to five years, with 71% of businesses experiencing this increase, driven by the enhanced technological capabilities of tax authorities and heightened regulatory pressure.
• 43% of tax inquiries lead to disputes, often resulting in prolonged and resource-intensive issues for businesses.
• Although most of the companies surveyed had a person responsible for tax matters, tax disputes still mostly ended up on the desks of the C-suite, thus increasing their workload.
• Inquiries cover a wide range of taxes, such as corporate, transaction, international, employment, and indirect taxes.
• Tax disputes can take years to resolve, often lasting three years or more, due to the complexity of issues and involvement across multiple jurisdictions.
• Advanced technologies, including data analytics, automation, and AI, are enabling more thorough and frequent inquiries by tax authorities.
• Increasing national and international tax regulations contribute to the rise in inquiries.
• Managing relationships with multiple tax authorities globally adds complexity and increases the likelihood of disputes.
• The Global Minimum Tax rules (Pillar Two) are expected to increase the burden on tax functions, prompting more inquiries and disputes, raising concerns about compliance and potential conflicts.
• AI is seen by many businesses as a potential tool to manage the growing workload of tax inquiries and disputes, though its adoption faces challenges.

Download the full report in English HERE