Practice areas

We advise our corporate clients in relation to their ongoing and strategic tax affairs.

Our approach to our advisory work is holistic; we will consider not only the corporate tax issues involved but also the other key legal and tax issues that may arise. Commercial considerations, company law issues and shareholder tax issues will often be critical to the matter in hand and we will ensure they are identified and addressed. Where appropriate, we enlist the expertise of our colleagues focusing in the areas of corporate, commercial and private client, to ensure that the proposals we make take account of the relevant issues in a commercial and constructive way.

We have extensive experience of advising in relation to holding company structuring, asset ownership (including intellectual property assets) and corporate governance. We regularly advise clients on substance and operational requirements to meet their corporate residence objectives.

We also have expertise in transfer pricing and thin capitalisation matters. We work with leading transfer pricing strategists and economists to provide our clients with comprehensive legal and strategic advice, enabling them to adopt realistic and justifiable transfer pricing policies and implement them appropriately. Transfer pricing issues often give rise to discussions with tax authorities, either prior to implementation or in the form of enquiries after the event.  We have the expertise to advise our clients effectively and constructively in relation to advance discussions with HMRC as well as enquiries and disputes.

Where other jurisdictions are involved, we work together with leading local counsel to propose the optimal structure for our clients across each of those jurisdictions.

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