KPMG webcast spotlights rising global tax controversy risks

KPMG’s June 23 webcast, Managing Controversy: The Tax Director’s View, brought together speakers from Amazon, HP and Intertek with Kathleen Agbayani and Jayme Reynolds of KPMG Washington National Tax. The one-hour session carried 1 CPE credit and focused on the growing volume of tax controversies multinationals are facing around the world, a signal that controversy work has moved deeper into the day-to-day load for tax teams.

The discussion centered on trends in tax and transfer pricing controversy, the current IRS audit environment, and how companies are assessing and addressing controversy risk. For KPMG professionals, that puts more pressure on the front end of the work. Tax directors now have to document positions, defend intercompany pricing and escalate weak points earlier, long before an audit notice turns a filing position into a dispute. The practical demand is shifting toward people who can handle technical tax issues, data discipline and client communication in the same engagement.

That pressure lines up with KPMG’s own 2025 transfer pricing year-in-review, which said companies should invest in advanced data management and technology solutions to support tax audits and reporting. KPMG said recent transfer pricing developments include new rules in Brazil, expanded guidance in the Middle East, increased disputes across the world and growing issues tied to tariffs and trade policy. For advisers inside the firm, that means more specialization around controversy readiness, more coordination across jurisdictions and more work helping clients build records that can survive scrutiny in more than one country at once.

The IRS Large Business and International Division remains the main audit home for many multinational matters, covering domestic and foreign businesses with U.S. tax reporting requirements and assets of at least $10 million. The IRS issued interim guidance on July 25, 2025, aimed at making LB&I examinations more customer-driven, consistent and efficient, and it also issued an advance pricing agreement announcement on March 27, 2025, showing APAs remain part of the dispute-management toolkit. The IRS has also said it wants to increase audit rates for large corporations, high-income individuals and large partnerships, which keeps transfer pricing at the center of controversy work for the firms that advise them.