Tax is now one of the most contentious areas in law. Tax authorities around the world are aggressively targeting corporates, multi-nationals, and high net-worth individuals with tax-related claims including assessments, with an increased focus on tax avoidance and evasion as well as suggestions (often unjustified) of criminal conduct.
Contentious areas include:
- Tax audits and investigations (domestic and cross-border)
- Pre-litigation strategy
- Settlement negotiations with tax authorities
- Tax appeals and judicial reviews
- Tax Treaty disputes and tax-related disputes under Bilateral Investment Treaties
- Mediation and arbitration of tax disputes
- Risk assessment and implementation of strategic measures
- Corporate offences and criminal issues relating to tax evasion
- Voluntary disclosure procedures
Dispute resolution and settlement of disputes
Our tax disputes practice is highly respected as one of the most experienced to advise taxpayers—whether corporates and their board of directors or individuals—on strategies to deal with tax authorities as well as on the management of tax controversies from the outset through litigation, mediation, arbitration, or settlement.
We have the best lawyers, who are top rated in their fields in complex tax-related disputes involving tax authorities in multiple jurisdictions.
Key partners
Recent Representations
- Sports clubs on complex tax/Employer Compliance Reviews including “image rights” and agency fees.
- Some of the world largest mining companies on multiple tax and VAT disputes and tax related arbitration.
- Several large multinationals in the oil and gas sector on various direct tax and VAT disputes and arbitration proceedings.
- International telecommunications corporations on significant taxation issues in multiple jurisdictions including complex tax treaty issues and competent authority procedures.
- Numerous UK-based media companies regarding tax status of presenters and scope of the IR35 regime.
- A major India-based conglomerate on various multi-jurisdictional tax related issues.
- A major online ticket platform in connection with German tax authority investigation involving EU and German tax and VAT issues.
- A major independent insurance brokerage in novel issues involving treatment of mixed membership and partnership income in a dispute against the UK tax authority
- A significant industrial metal trader in a regulatory dispute with the London Metal Exchange over the suspension and cancellation of trading in the nickel market.
- An international banking entity in complex cross-border issues regarding tax treatment in the context of ISDA securities lending arrangements.
- A major retailer post-restructuring on complex VAT-related issues involving the HMRC.
- A major telecommunications company in a litigation in the Commercial Division of the Supreme Court of the State of New York to recover indemnification for a settlement entered into with Mexico’s tax authority to resolve liabilities incurred by a predecessor subsidiary.
- Family Trusts regarding restructuring and related tax risks.
- High net worth individuals on joint IRS/HMRC fraud investigations.
- UK based corporates in ongoing litigation in the UK tax courts.
- High net-worth individuals on various tax-related disputes and risk assessment issues involving various jurisdictions.
- Financial services corporations on German, Swiss, and Finish “cum ex” related tax/tax credit disputes.
- Multijurisdictional companies on complex financing arrangements and corporate structuring in various offshore jurisdictions.
Partners
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