Tax is now, more than ever before, a major contentious area.  Tax authorities around the world have become more aggressive in targeting corporates, multi-nationals and high net worth individuals with tax related claims including assessments, with an increased focus on tax avoidance and evasion.

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
  • COP 8 and COP 9 disclosures

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, and the management of tax controversies from the outset, through litigation, mediation, arbitration or settlement.  We also have top rated advisors in complex tax-related cross-border disputes under Tax Treaties and Bilateral Investment Treaties involving tax authorities in multiple jurisdictions.

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Recent Representations

  • Sports clubs on complex tax/Employer Compliance Reviews including “image rights”.
  • 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.
  • 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.
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