This has led to increasing scrutiny of tax affairs and an international rise in tax disputes and investigations.
Our team focuses on resolving these disputes and investigations. Our work ranges from advice on information requests, global investigations, tax audits and dawn raids to litigation and settlement of tax disputes, including through arbitration.
We work as one team, combining knowledge and experience from our award-winning corporate tax and dispute resolution practices across our offices and the firm's StrongerTogether partner law firms.
We provide quality advice on complex, high-value tax disputes across all taxes and sectors for both local and international clients.
Our experience covers corporate tax, transfer pricing and diverted profits tax (DPT), taxation of the digital economy, VAT and other indirect taxes, EU and contractual claims, employment taxes, state aid and public law/judicial review. We advise on civil and criminal investigations internationally.
We adapt our strategy to your specific needs. We often settle disputes without litigation, but we are also adept at taking cases to the courts at every level, including the European Courts.
We helped:
- Multiple multinational groups facing investigations into the application of the UK’s loan relationship unallowable purposes rules to their financing arrangements.
- A multinational US-headed group defend their European sales and distribution companies against allegations by the French tax authorities that the structure relied on an inappropriate transfer pricing model and lacked economic substance.
- Multiple multinational consumer products and technology companies contest the imposition of (and adhere to compliance requirements related to) extraterritorial German withholding tax on royalty payments between non-resident companies for IP registered in Germany.
- An international group on a multi-faceted dispute with the UK tax authorities, including on the correct interpretation of an advance pricing agreement.
Our thinking