Taxpayers and tax authorities rarely agree on much. They do, however, agree on one key point: the number of large, complex cross-border tax disputes is increasing and will likely continue to rise, and something needs to be done to stem their flow.At the same time, the large business taxpayer community is on the brink of another set of fundamental changes in how they calculate, pay and report taxes under the BEPS 2.0 Pillar One and Two. These changes are complex, and the path to implementation has been challenging. If current trends persist, the number of tax disputes is likely to...