The Return of Tax Litigation: Why Disputes Are Surging

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.

WTL Research Center

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.

Source Based on reporting by World Tax Lawyers (February 20, 2026) . This piece is an original analysis by the WTL Research Center and does not reproduce the source.

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