T This report analyzes the resolution of a tax dispute involving a supporting oil and gas company in the subsea industry, which is a client of the consulting firm where the author served as an advisor. the dispute originated from the issuance of a letter of request for explanation of data and/or information (sp2dk) and subsequently escalated to a formal tax audit. this study adopts a qualitative case study approach to examine the factors contributing to dispute escalation, the disparity in tax findings between the sp2dk stage and the pre-tax audit result notification stage, and the strategies employed for dispute resolution. the analysis indicates that information asymmetry, differing interpretations of material tax compliance, and the application of article 26 withholding tax without adequate permanent establishment assessment were key drivers of the significant increase in tax adjustments. a resolution strategy grounded in the application of tax treaty provisions as lex specialis, supported by substantive economic evidence, administrative compliance, and non-confrontational communication, proved effective in reducing tax exposure and achieving a more proportionate administrative settlement.