London · Global Network
World Tax Lawyers
Cross-border tax disputes have risen by more than 40% since 2020. Our litigation leads set out the drivers — and what general counsel should be doing about it.
The rise in cross-border tax disputes is structural, not cyclical. Three factors explain it: the weaponisation of transfer pricing by cash-constrained tax authorities; the new substance standards under BEPS; and the proliferation of unilateral digital services taxes.
Analysis
Twelve months in, the first wave of European Pillar Two adopters have exposed both the strength of the GloBE framework and its sharpest edges. A field report from the WTL Council.
Apr 2026
Analysis
The OECD's substance-over-form revolution has reshaped transfer pricing analysis. Our members set out a practical framework for groups facing audit.
Apr 2026
Analysis
The transitional CbCR safe harbour sunsets in 2026. Our Pillar Two leads analyse the post-safe-harbour landscape.
Jan 2026