Hello everyone. My name is Peter De Re, Global Tax Director at P.WC. in Brussels, and I welcome you to the PWC

Taxbyte podcast series. In this series of podcasts, we discuss relevant developments in the international

tax world with experts in the field. You can follow this

podcast on Apple, Spotify or via the PWC website. Today, we are going to talk about the developments

in the area of tax controversy and tax audits. In a previous edition, we already touched on the

development specifically on beneficial

ownership, but in this episode, we will take a broader look. And I have with me three very good

experts in the field today. First of all, we have Veronique de Brabantor, attorney at PWC legal,

and specialized in creative ways to resolve tax disputes and tax litigations.

With us also today, Evie Gates, Director Global Tax at PwC,

and Evie is engaged in a lot of the recent withholding tax disputes

focusing on beneficial ownership, but also on tax abuse.

And of course also Bram Markey, Transurricing Director at PWC and leader of the

PWC Belgium tax controversy practice.

Well, many groups are confronted with tax audits clearly in Belgium and abroad.

So the purpose of this podcast is to look at some of the recent trends, but not all doom

and gloom as we will share some best practices on what you can do to prevent or resolve disputes as well.

And to start on this topic, I have a first question for you, Bram.

So at the time when businesses are recovering from the pandemic, isn't it strange that especially now, we see an uptick in tax audits and disputes?

Well, Peter, it's definitely unpleasant because groups and taxpayers, they are struggling to prioritize already the scarce resources.

But actually, it's a trend that started before the pandemic where we did see an increase in audit activity, more scrutiny, new techniques for all the things.

So it's not new, but it's definitely unpleasant because the last thing that you want to have on your plate when you're already struggling and prioritizing is a lengthy

...