Tax

Complex group reorganisation

Advising on the UK tax considerations of a proposed group reorganisation, including advising on structuring and the application of the general anti-abuse rule.

Offshore fund manager with onshore operations

Advising on the application of the UK’s anti-avoidance rules to the flow of funds within the fund structure, including consideration of the rules on disguised investment management fees.

Cross-border supply of intermediary services

Advising a UK intermediary on the VAT place of supply rules applicable to a high-value transaction where the intermediary brought together a seller in Portugal and a buyer in Italy.

High-profile takeover

Advising on the UK tax considerations of a high-profile company takeover which required tax clearances to be obtained from HMRC.

Image rights

Acting for high-profile clients on tax enquiries into their image rights structures involving offshore vehicles.

Tax and state aid

Advising multiple clients in a dispute with HMRC and the European Commission concerning the compatibility of the UK’s rules on controlled foreign companies with the EU’s rules on state aid.   

Tax enquiries, investigations and disputes

Guiding clients through the rising number of HMRC enquiries, investigations and disputes concerning the UK’s direct and indirect taxes. 

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