This article discusses whether international tax controversy is set to increase in Asia, whether there are any characteristics of tax controversy in the region, and how enforcement trends will evolve. The author contends that the combination of limited tax administration capacity, particularly of human resources, and a strong desire to secure tax revenue could lead to disagreement between tax authorities and taxpayers. He argues that it is beneficial to understand the enforcement trends and behaviour patterns of tax authorities as an evolutionary process in the step development of the capacities of tax authorities.