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Corporate tax

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  1. United Kingdom – Leading tax law firms: Corporate tax
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Freshfields Bruckhaus Deringer LLP handles a steady stream of large corporate transactions, investment funds and private equity work and capital markets transactions. The tax team is also privy to the increasingly tumultuous legislative landscape and advises its blue-chip client base on tax-risk management, strategic planning and the potential impact of various legal and political developments. Headed by David Haworth, the department fields specialist partners in a number of areas. Helen Lethaby has particular expertise in fund and deal structuring, acting for a range of global investors; Paul Davison leads the finance tax group; Colin Hargreaves, Sarah Falk and Jill Gatehouse are consistently involved in some of the market’s largest corporate finance transactions and restructurings; and Murray Clayson heads the firm’s transfer pricing unit. Significant clients have included household names such as Anheuser-Busch InBev, BT, Tesco, Betfair Group, BP and Honeywell International. Helen Buchanan leads the contentious tax group, but also maintains an active non-contentious practice; Peter Clements and David Taylor are also key contacts.

Slaughter and May’s tax group is regularly involved in some of the most prominent corporate deals in the London market and has also seen a steady increase in the amount of tax advisory work undertaken in 2016-2017. In one particularly stand-out matter, Mike Lane advised Equinix on the tax aspects of the acquisition of Telecity Group, and most importantly, on the separation and sale of eight of the target’s assets, which was a condition for obtaining clearance for the acquisition from the European Commission. Dominic Robertson acted for GlaxoSmithKline in relation to its joint venture with Verily Life Sciences and developed the tax relief strategy associated with the joint venture agreement. Other notable highlights include Steve Edge’s work for Vodafone Group in connection with the merger of its Dutch operations with Liberty Global, and Tony Beare assisting DONG Energy with the UK tax aspects of a 50% disposal of interest in the Race Bank offshore wind farm. Department head Sara Luder handles both transactional tax matters and tax advisory work, while William Watson has extensive experience of the real estate and oil and gas sectors. Jeanette Zaman and Gareth Miles are also contacts in the department.

In line with the wider firm’s strengths, Allen & Overy LLP’s tax team is particularly strong in advising on the tax aspects of capital markets, structured finance and international M&A transactions. While the transactional support practice has been particularly busy in 2016-2017, the team has also noticed a marked increase in stand-alone tax advisory work. Indeed, as an example of both sides of the non-contentious practice, joint head Christopher Harrison assisted Bermuda-incorporated VimpelCom with the tax aspects of its joint venture arrangement with CK Hutchinson Holdings and also handles post-transaction advisory work for the client. Vimal Tilakapala jointly leads the group and acts for a list of global financial institutions in relation to the tax aspects of various equity financing transactions and structured product portfolios, and also provides ongoing advice on cross-border financing arrangements. Charles Yorke and Lydia Challen were instructed by Clydesdale Bank plc in relation to its demerger from National Australia Bank and subsequent IPO, and also advised on the client’s new regulatory capital instruments. James Burton, who specialises in real estate and direct tax, was promoted to partner in 2016.

Well-engaged and very highly regarded’ in the area, Clifford Chance handles the tax aspects of a wide range of financing, capital markets and investment transactions, and has been especially active on the advisory front in 2016-2017. The group is ‘very responsive to new announcements and proposals’ in the market, as evidenced by its active Brexit-related global structuring and supranational taxation advice practice. Department head Chris Davies is acting for AIG in relation to Project Bloodhound, which has involved a structured transaction accommodated to three separate tax jurisdictions, whereby the client will acquire a significant loan portfolio backed by UK commercial property. In 2016, Nicholas Mace assisted Sainsbury’s with the tax aspects of a unique structure in relation to the client’s £1.4bn takeover of Home Retail Group, which combined the establishment of a new holding company, a court-approved scheme of arrangement, a capital return and a takeover into a single process. Anthony Stewart provides ongoing advice to Investec Bank regarding its range of structured products, while David Harkness is instructed by clients such as ICAP and Deutsche Bank. Dan Neidle is also highly recommended.

Herbert Smith Freehills LLP’s tax department is anchored by a transactional team that has expertise in M&A, fund formation, private equity work and restructuring. It is particularly well-positioned to advise on transactions involving heavily regulated sectors such as insurance and upstream energy. Indeed, practice head Isaac Zailer advised E.ON on the tax aspects of the $1.72bn disposal of the client’s entire North Sea oil and gas business. Additionally, Howard Murray is acting for EDF and its subsidiary, NNB Generation Company, on the tax structuring and financing associated with the Hinkley Point C project. In the real estate space, Neil Warriner acted for Qatari Diar in connection with the negotiation and creation of tripartite rental property joint venture, with assets of £1.4bn and plans to develop and manage 4,000 homes. William Arrenberg was instructed by Brookfield Property Partners to draft and negotiate the tax provisions and protections in relation to the £560m acquisition of the entire issued share capital of the unit-holders in the Jersey Property Unit Trust. Aurell Taussig is another key contact and advised Man Group on its $232m acquisition of Aalto Invest – a firm with offices in the US, UK and Switzerland.

Linklaters LLP’s tax department has a wealth of ‘technical expertise and the ability to apply it to a variety of commercial circumstances’. It handles taxation across a range of specialisms, from corporate and financing transactions, to advising asset managers and investment funds, and also has a dedicated private equity tax structuring practice. As an example of the group’s private equity work, the ‘calm and creative’ Mark Kingstone assisted TDR Capital with the structuring of its acquisition of Euro Garages and the subsequent merger of that business with the client’s existing forecourt retail business to form Intervias. In the funds space, Kingstone acted on the tax structuring and documentation of PW Real Estate Fund III, which reached its hard cap of €1.5bn at its second close, in 2016. Lynne Walkington acted for Deutsche Börse AG on the tax and holding structure in relation to its merger with London Stock Exchange Group plc. A ‘commercial and technical problem solver’, Yash Rupal heads the practice group, which is also rated for its ‘impressive strength in depth’, fielding highly recommended associates such as Sam Lintonbon and senior associates such as Sarah Lindley. Partner Dominic Winter is another key contact in the tax department.

Ashurst is ‘technically very good across all areas of tax, with a commercial and practical approach’, covering a range of funds, financial products, transactional tax and cross-border advisory work. The team has a notable presence in the energy and infrastructure sector, and Nicholas Gardner advised China General Nuclear Power Corporation regarding the tax aspects of an investment into Hinkley Point C, in addition to the establishment of a joint venture for the development of two other nuclear power stations. Gardner also acted for Spanish conglomerate Abertis Infraestructuras in relation to the tax structuring of the €948m acquisition of a 50% interest in a Chilean toll road from Alberta Investment Management Corporation. With experience in a huge range of corporate tax work, Alexander Cox is ‘truly excellent’ and assisted Inflexion Private Equity with the tax structuring in relation to the first and final closings of two new PE funds. Simon Swann specialises in real estate taxation, while Paul Miller handles the tax aspects of various financial products.

In terms of personnel, Baker McKenzie boasts one of the largest tax practices in London and further bolstered its offering in 2016 with hires from EY, KPMG and Deloitte. It combines a traditional transactional tax offering with stand-alone tax planning and transfer pricing units. Patrick O’Gara led a cross-border team which acted as special tax counsel on the transactional issues and post-deal tax advice of the $18bn Willis Towers Watson merger. Similarly, James Wilson advises Coach as global tax counsel on the post-acquisition integration of the Stuart Weitzman business. Richard Fletcher heads the firm’s transfer pricing group, which has worked alongside the tax department to handle global restructuring for multiple household name clients in the tech, online business and manufacturing sectors. As one of the founding members of the transactional tax group, Alistair Craig is a key contact and acts for clients such as Barclays, Accenture and Platinum Equity. James MacLachlan and Geoff Kay both retired.

Hogan Lovells International LLP’s tax lawyers ‘get things right and respond in good time’. In 2016, the department hired to strengthen its economics and transfer pricing sub-group, and also brought on Elliot Weston from Gowling WLG as well as two senior associates and three associates. Representative of the work he’ll bring to the firm, Weston acted for Singaporean client Keppel DC REIT on the tax structuring of an investment into a data centre in the UK. The tax team is capable of pitching and winning work against Big 4 firms, which is how Philip Harle won an instruction from Lloyds Development Capital and NewCo, as an acquisition vehicle, which he advised in relation to a £12m investment in Blue Bay Travel. The practice is also active in the finance space, and acts as UK tax advisor to The Department of Education in relation to its £4bn securitisation of income-contingent student loan repayments. Karen Hughes is another key contact and Philip Gershuny retired at the end of 2016.

The tax department at Macfarlanes LLP comprises five key sub-groups: group tax, M&A, investment management, real estate tax and remuneration. The team also has dedicated practitioners in specialist areas such as transfer pricing and VAT, which have been strengthened by the arrivals of new practice heads; Batanayi Katongera from Olswang, and Chris Mortimer from PwC, head transfer pricing and VAT, respectively. In the M&A space, Ashley Greenbank advised Verizon Communications on the tax structuring in connection with its $2.4bn acquisition of Fleetmatics Group and subsequent group reorganisation. James McCredie assisted Legal & General Group with the establishment and tax structuring of a £600m real estate holding fund in connection with a development joint venture with a Dutch pension fund. Damien Crossley heads the tax department and advised Silverfleet Capital on the gamut of tax structuring and post-transaction issues in connection with the client’s acquisition of Lifetime Training Group. In 2016, Kirsten Prichard Jones joined as senior counsel from Nabarro and Peter Abbott was made partner.

Norton Rose Fulbright’s tax department has a reputation for acting on international transactions, especially in emerging markets, and also has expertise in the property and funds areas. It is heavily focused on several key industry sectors, which include energy, insurance, technology, rail and aviation. Practice head Dominic Stuttaford has advised Barclays Bank plc on multiple matters in 2016-2017, having handled the tax aspects of the client’s sale of its Egyptian operations, the disposal of its French operations to Annacap and also on the sell-down of its South African operations. Specialising in real estate and funds work, Angela Savin acted for Civitas Social Housing in connection with the tax structuring of the investment-client’s £350m IPO. In the energy sector, Matthew Hodkin advised Endeavor Energy on the tax risk allocation of the funding and construction of a dual-fuel power project in Ghana. Chris Bates is another key contact and has experience of advising financial institutions on a range of structured transactions.

Reliable and responsive’, Simmons & Simmons handles tax advisory work and transactional support, and is especially active in the areas of financial services, life-sciences and TMT. In addition, the tax team is particularly recommended for its expertise in investment funds, and in 2016 Martin Shah acted for Oil and Gas Climate Initiative in relation to the tax structuring of a $1bn collaborative investment fund aimed at addressing climate change. On the advisory side, Shah also advises a number of US asset managers on the transfer pricing as well as direct and indirect tax issues of establishing their UK operations. Department head Nick Cronkshaw, who is ‘extremely able’, advised APG Rechtenbeheer on the merger of two London residential projects to form a £1.4bn joint venture with Delancey and Qatari Diar. Mark Sheiham specialises in the tax aspects of structured finance and capital markets transactions and continued to assist Greensill Capital (UK) in relation to tax issues arising from its supply chain financing programme. Hatice Ismail was promoted to partner in 2016.

The tax department at Skadden, Arps, Slate, Meagher & Flom (UK) LLP is best known for handling the tax aspects of cross-border M&A and private capital matters, especially where there are dual US and UK issues. James Anderson heads the firm’s European practice group and is regularly instructed by alternative asset managers and financial institutions. He advised Phoenix Group Holdings on the tax aspects of its £935m acquisition of Abbey Life Assurance Company and the related rights issues; similarly, he is acting for Banco BTG Pactual in relation to its sale of Swiss banking group BSI. Alex Jupp made partner in 2016 and was instructed by The Coca-Cola Company as part of a multi-jurisdictional team that handled the combination of Coca-Cola Erfrischungsgetränke with Coca-Cola Enterprises and Coca-Cola Iberian Partners. He also acted for Ctrip.com International on the tax aspects of its $1.7bn acquisition of Skyscanner Holdings. The tax team also handles tax advisory and restructuring work for hedge funds and high-profile investment management firms.

Travers Smith LLP fields a sizeable, ‘hard working, knowledgeable and practical’ tax team with specialisms in corporate finance and transactions, funds and asset manager work and real estate and infrastructure taxation. Simon Skinner, the department’s head as of 2017, was instructed by Melrose to advise on the tax aspects of its group restructuring in addition to the structuring of a multibillion-pound capital return to the client’s shareholders following the sale of its Elster Water metering division to Honeywell International. Additionally, Elena Rowlands was made partner in 2016 and acted for The Pensions Infrastructure Platform (PiP) in relation to the tax structuring of its PiP Multi-Strategy Infrastructure Fund. Emily Clark undertakes advisory work for asset managers and funds clients and assisted Medicxi Ventures with the tax structuring of its formation as an independent life sciences firm. Simon Yates also handles a range of advisory and high-value transactional work. Russell Warren and Kathleen Russ are tax partners specialising in private equity transactions and Richard Stratton is another key contact.

With extensive experience of ‘the breadth of real estate transactions’, Berwin Leighton Paisner LLP specialises in real estate taxation, including the tax aspects of real estate investment funds. Elizabeth Bradley, who leads the global tax group, acted for China Life and Brookfield on the £346m acquisition of the corporate structure owning Aldgate Tower, and also assisted China Life with the joint venture and asset management arrangements in connection with the acquisition. The department head also worked alongside Matthew Poole in relation to the tax structuring of Time Inc’s £415m sale of IPC Magazines Group to a joint venture. Richard Harbot is known for providing ‘high-quality, commercial tax advice’ to clients such as household name private equity clients and multinational corporates. John Overs and Paul Shaw are also partners in the tax department. Michael Wistow left for White & Case LLP in 2016 and Neal Todd and Gary Richards both retired. In 2017, the team hired Mark Brailsford from Osborne Clarke LLP.

Following a three-way merger with Nabarro and Olswang, CMS’s tax department has significantly expanded, both in terms of personnel and in breadth of specialism and experience. The department now fields 13 partners and has expertise in areas such as real estate taxation, tax planning in connection with a wide range of corporate and private equity transactions, fund structuring, employee incentives and IP and technology tax issues. Richard Croker leads the corporate tax team alongside department co-head Stephen Hignett, the latter of whom has been involved in multiple, complex demergers and reorganisations in 2016. Similarly, on the corporate transactional side, Sam Dames, Mark Joscelyne and Aaron Fairhurst have experience of the gamut of M&A, finance and private equity work. Clíona Kirby maintains an active tax advisory practice and advised DV4 Limited on the tax structuring of a residential investment partnership with Qatari Diar Real Estate and a Dutch pension fund asset manager. Additionally, Nick Burt, Jim Hillan and the ‘practical and solution-focused’ Graham Chase have particular expertise in real estate and funds taxation.

DLA Piper’s tax team is ‘adept’ at handling international M&A, restructurings and real estate and finance transactions, and also has a dedicated transfer pricing group. Richard Woolich leads the department and was instructed by Aareal Bank to advise on the UK tax aspects and manage the international tax advice in relation to the refinancing and restructuring of Invesco Fund’s EU property portfolio. ‘A consummate professional’, Paul Rutherford acts for Heineken Group in connection with the tax efficiency of its offer to acquire a securitisation group, Punch Taverns A, from Patron Capital. Neville Wright has expertise in the tax aspects of real estate transactions and advised Oxford Properties on its sale of the Green Park business park to Singapore-based Maple Tree Investments. The transfer pricing group is jointly led by Joel Cooper and Randall Fox.

With expertise in providing dual UK and US corporate tax advice to investment fund clients, Debevoise & Plimpton LLP is ‘excellent for full-service work’ and is able to ‘effectively communicate commercial advice’. One of the ‘best tax brains in the City’, Richard Ward advised CPP Investment Board on the tax issues and incentive plans in connection with the client’s $1.1bn acquisition of Ascot from AIG. He also acted for Park Square Capital Partners regarding the tax provisions of the Park Square Capital Partners III fund formation. Matt Saronson is recognised for his ability to ‘break down arcane topics in a simple way’ and was instructed by AltaOne Capital to draft the economic provisions in an acquisition agreement for 37.6% of the share capital of Cegrid Group. Cécile Beurrier has experience in the tax aspects of debt and equity offerings and advised Pernod Ricard on the US tax issues associated with its successful close of a €600m Eurobond offering.

Kirkland & Ellis International LLP fields a sizeable UK tax team with specialisms in private equity, real estate and credit transactions. Additionally, the group has experience in the tax aspects of financial restructuring and fund formation, and practice head Jonathan Kandel recently acted for IK Investment Partners in relation to the final close of its eighth mid-cap fund, IK VIII Fund, which claims capital commitments of €1.85bn. In the real estate and M&A space, Kandel advised GIC, the sovereign wealth fund of Singapore, in relation to its €2.4bn acquisition of P3 Logistic Parks. Ian Ferreira, Frixos Hatjantonas and Dulcie Daly are also recommended. The tax department followed substantial growth in 2015 with the recruitment, in 2016, of Timothy Lowe from Linklaters LLP, while, also in 2016, Oliver Currall left for Sidley Austin LLP.

Latham & Watkins handles the gamut of corporate tax issues involving M&A, private equity and capital markets transactions, especially where there are multiple jurisdictions involved. As an example, in 2016, London-practice head Sean Finn advised Allergan in relation to the $40.5bn sale of its global generic pharmaceuticals business to Teva Pharmaceutical. He also acted for ViaSat in connection with the structuring agreements of a joint venture with EutelSat Communications. Karl Mah also has experience of cross-border M&A, and advised ICU Medical on its $1bn acquisition of the Hospira Infusion Systems business from Pfizer, a deal that was structured as a cash/stock combination and required tax structuring appropriate to over twenty different jurisdictions. He was also instructed by J.P. Morgan as lead arrangers in relation to the €6.4bn refinancing of Pirelli. Sarah Gadd, a specialist in employment tax, was promoted to counsel in 2017.

McDermott Will & Emery UK LLP has a stand-alone tax practice that provides transactional support in addition to offering tax advisory services to multinational corporates, financial services institutions and ultra high-net-worth individuals. The department was joined by Russell Hampshire in 2016, who had previously served 16 years as a tax partner at KPMG. He provides ongoing advice to multiple US multinationals concerning the impact of various action items of the base erosion and profit shifting (BEPS) initiative. James Ross assisted Irving Oil with the tax aspects of its acquisition of the Whitegate oil refinery in Ireland through a competitive auction process. Ross was also instructed by Praxair in relation to its acquisitions of Yara International and NOxBOX. Matthew Herrington is the team’s transfer pricing specialist and Tom Scott is another key contact in the practice group. Olam International, Universal Health Services and Electronic Arts are clients.

A cut above most other specialist tax firms’, NGM Tax Law LLP is a boutique tax outfit that is regularly instructed by other law firms in relation to particularly complex tax issues, and also acts directly for banks and multinational corporates. The team comprises a total of 12 partners and consultants bred from international, tax-focused law firms, including Magic Circle and Big Four firms, and has ‘deep industry knowledge’ of corporate M&A, non-contentious trusts, private equity work, international restructuring and non-transactional tax planning. In 2016, firm-founders Mark Nichols and Keith Gregory were instructed by a South-east Asia-based corporate finance house to devise a particular structure allowing relief under a specific HMRC assurance programme, which the client had not previously qualified for. Simon Meredith acted for a UK law firm on behalf of the sellers in connection with the sale of Sipsmiths and helped craft a structure to maximise the amount of tax relief for a transaction that was paid in instalments.

The tax department at Stephenson Harwood is known for its ‘responsiveness and good technical knowledge’ in a set of key areas including real estate, M&A, investment funds and transportation and asset finance. Indeed, practice head and ‘proactive problem solver’ Hugo Jenney is assisting Transport for London with the direct and indirect tax aspects of the £15bn Crossrail development. He also provided tax advice to Mount Eden Land in relation to the £581m senior debt and mezzanine Eurobond refinancing of the high-profile Langham Estate. In 2016, Maryanna Sharrock advised Acadia Healthcare on the tax provisions and stamp duty filing in connection with its £1.3bn acquisition of the Priory Group. Another active member in the tax team, John Meehan is acting for Osprey Equity Partners in relation to the structuring and launch of a new REIT. The firm is continuing to invest in the tax practice and added four new associates in 2016-2017.

The tax group at Weil, Gotshal & Manges (London) LLP is ‘an integral part of a very strong overall corporate practice’, with expertise in private equity, asset managers and private funds, structured finance and M&A. Specialising in funds work, David Irvine ‘combines deep technical knowledge with an ability to express complex subjects in straightforward terms’. Oliver Walker, ‘a plain speaking and technically excellent’ partner, has particular expertise in private equity transactions and acted for OMERS Private Equity in relation to the tax aspects of the sale of V.Group to Advent International. Senior consultant Andrew Norwood has built a strong reputation advising on the taxation of securitisation transactions and is instructed by well-known asset managers in connection with the tax structuring of various collateralised loan obligation (CLO) transactions. Additional clients include Paragon Offshore, L’Oréal and Qatar Airways.

With experience of the tax aspects of real estate, financial services, private equity, restructurings and a range of other corporate transactions, White & Case LLP provides clients ‘a seamless working dynamic between the corporate tax team and the general corporate team’. The group also offers a stand-alone advisory service and has also developed expertise in advising foreign governments in relation to their tax legislation. Prabhu Narasimhan, who is ‘technically gifted, but at the same time very commercial’, is acting for Kaupthing Bank in relation to its Icelandic insolvency proceedings and international restructuring in what was one of the largest-ever bank insolvencies. Led by Narasimhan, the firm’s tax group now acts as primary tax advisers to Novator Partners, a role which covers both transactional and advisory work. Michael Wistow, a new hire from Berwin Leighton Paisner LLP in 2016, is acting for Bupa on its acquisition of 380 dental practices owned by Oasis. Peita Menon heads the UK tax practice and is also recommended.

Addleshaw Goddard’s tax department handles a wide range of corporate transactions with specialisms in real estate, financial services and private equity. London practice head Elaine Gwilt advises on a significant number of M&A and real estate transactions. In the real estate space, she acts for certain funds managed by Aberdeen Asset Management and was involved in the £43m acquisition of the Albert Dock in Liverpool. Gwilt also provides a tax advisory service to private equity houses. Paul Concannon was promoted to partner in 2016 and advised a high street lender in connection with the tax aspects of the reorganisation of multiple offshore private branches. Peter Sayer is also active in the real estate sector, with expertise in student accommodations, and also assisted the management team of Plinian Mining Group with the tax structuring and establishment of a new partnership fund.

Akin Gump Strauss Hauer & Feld is particularly strong at handling the tax issues encountered by hedge fund clients and has extensive experience of international restructurings. It also provides stand-alone tax advice and works closely with its Geneva office, which provides a stream of investment fund and international banking clients. In one of the department’s flagship deals, Stuart Sinclair acted for a group of investment and pension funds, insurance companies and banks as bondholders of three major, failed commercial Icelandic banks in connection with the proposed restructuring of the failed bank estates; Sinclair simultaneously lobbied for specific amendments to Icelandic tax law, which were enacted. He also worked alongside Sophie Donnithorne-Tait to advise OM Asset Management and Old Mutual in connection with the UK tax aspects of a $400m bond issuance and a subsequent $213m secondary offering.

Eversheds Sutherland (International) LLP’s ‘technical ability and relevant industry knowledge’ in investment funds, the tax team's core area of expertise, ‘must be considered unique’. Cathryn Vanderspar advised UK Mortgages Limited on the cross-border structuring of a public securitisation structure backed by £300m of buy-to-let mortgages, and also assisted the client with its investment in a separate securitisation structure with exposure to newly originated owner-occupied mortgage loans. In 2016, corporate tax head Ben Jones advised Greencore Group on the UK tax aspects of a £440m rights issue to fund the acquisition of Peacock Foods. ‘One of the sharpest, most pragmatic, effective and courteous tax lawyers in the City’, Camilla Spielman acted for Standard Life Investments in relation to the merging of two property authorised investment funds, in addition to assisting in the restructuring and merger of the respective feeder funds, following the client’s acquisition of Ignis Investment Management. John Buckeridge is also recommended for funds taxation.

Fieldfisher’s tax team has ‘exceptional capabilities in corporate tax, in particular in relation to corporate finance transactions’ and is driven by dedicated strengths in the TMT, life sciences and financial services sectors. Derek Hill heads the tax structuring group and is instructed by Alternative Resolution Consultancy, a joint venture aimed at assisting individuals facing financial hardship as a result of investments in tax-structured film finance structures. Specialising in corporate finance transactions, Andrew Prowse has a ‘superb grasp of business taxation’ and handles M&A transactions for various TMT and financial services clients in 2016-2017. Additionally, Nick Noble has provided tax advice to financial services clients in relation to a number of lending transactions. Graeme Nuttall OBE is another contact in the practice group and has extensive experience of structuring employee ownership schemes.

Mayer Brown International LLP has a diverse and proactive tax practice, which ‘stays at the forefront of industry trends’ in its core areas including real estate and investment funds. Sandy Bhogal leads the London tax team and is highly regarded in the market for his ‘technical expertise, commercial awareness and negotiating skill’. In 2016, he advised Rina SpA on the tax aspects of the £119m acquisition of the entire share capital of Edif Group, in addition to the subsequent restructuring. The department head also has a discrete tax advisory practice focused on the funds and financial services sectors. With expertise in the taxation issues around corporate finance, M&A and group reorganisations, James Hill acted as legal adviser to Dah Chong Hong in relation to its $350m acquisition of Li & Fung’s consumer and healthcare distribution business in mainland China and South East Asia. Additional clients for which the team has performed significant tax work include Unilever, Moody’s and Macquarie Bank.

From 2014, when the UK tax team took its current shape, Ropes & Gray LLP has gained recognition for its work in the areas of private equity, fund formation, credit and real estate. In 2016, Andrew Howard was promoted to partner. He is assisting Virgin Media with the tax aspects of multiple innovative securities transactions and, on the M&A side, he was instructed by firm-client Pfizer to handle the tax issues related to its $1.58bn acquisition of certain development and commercial rights from AstraZeneca. The London team is led by Brenda Coleman, who is acting for CVC Credit Partners in relation to the concurrent formation of three funds, and was also recently appointed as fund formation counsel for Nordic Capital’s Nordic Capital Fund IX. She has also advised on the tax aspects of multiple M&A transactions in 2016-2017, and assisted Mezzvest with the tax structuring of a European senior credit platform.

The corporate tax department at Shearman & Sterling LLP is regularly involved in the firm’s largest M&A, securities and private equity deals. Practice head Simon Letherman acted for a consortium of underwriters, led by HSBC Securities (USA), in connection with HSBC Holdings plc’s $7bn issuance of fixed and floating rate senior unsecured notes. In the M&A space, he advised Liberty Global on the deal structuring and subsequent share listing relating to its acquisition of Cable & Wireless Communications. Letherman also assisted General Electric Capital Corporation with the UK and Indian tax aspects of its $300m sale of GE Capital Services India and GE Money Financial Services to Plutus Financials. Other notable clients include Société Générale, Intercontinental Exchange and Qatar Investment Authority. Sarah Priestley joined Goodwin in 2016.

Sidley Austin LLP’s UK tax department has experience of a range of corporate transactions, particularly in the private equity space. Oliver Currall joined the team from Kirkland & Ellis International LLP in 2016 and advised TowerBrook Capital Partners and KKR on the tax structuring of a joint mandate to invest €250m for a minority stake in OVH. Will Smith, who has a transactional and advisory practice, handled the tax aspects of Wells Fargo Bank’s purchase of its new European headquarters; his advisory work has focused on assisting investment fund clients with issues arising from potential changes in the UK tax regime. Drew Scott leads the London tax group and has experience of contentious and non-contentious tax matters. Graeme Harrower retired in 2017. Additional key clients include BlackRock, Tai United and Bank of Cyprus.

The ‘knowledgeable and commercial’ corporate tax team at Taylor Wessing LLP is considered by some as ‘a go-to practice for real estate special purpose vehicle’ tax structuring. Indeed, Peter Jackson advised Tritax Big Box REIT on two separate placings totalling £550m, in addition to the tax structuring of a number of acquisitions of holding vehicles and subsequent property extractions and group reorganisation. Other areas of expertise include technology, private wealth and private equity. Robert Young, who replaced Jackson as practice head in 2017, acted for onefinestay in relation to its sale to AccorHotels and also coordinated the provision of French and US tax advice. Nikol Davies left the firm to return to Australia in 2017, but Graham Samuel-Gibbon joined from EY, where he had been a director in the international tax services department. Richard Carson is an active consultant in the department.

Bird & Bird LLP’s tax department regularly acts for the firm’s hi-tech and venture capital-backed client base, and has particular specialisms in international-facing IP tax, employment and shareholder tax and the taxation of solar energy projects. Practice head Mat Oliver has acted for a number of renewable energy developers, such as Bluefield Partners, in relation to their UK solar energy developments. Colin Kendon specialises in employee and shareholder taxation and has experience of group reorganisations and management buyout transactions. Past clients have included Tomorrow London, Altus UK and Axio Data Group.

Burges Salmon LLP has a broad tax practice that has traditionally supported the firm’s transactional groups, but is increasingly providing tax-driven restructuring advice, especially to clients in the power and energy industries. Nigel Popplewell has particular experience in property-related tax and corporate restructurings and has advised YTL Hotels on the various tax aspects of a number of the client’s recent hotel and property acquisitions. John Barnett has expertise in private equity, investment funds, remuneration and tax planning, and has been instructed by clients such as Octopus Investments, UBS and Yeo Valley Group.

Cadwalader, Wickersham & Taft LLPpunches way above its size’ in the UK tax market and has particular experience of investment and fund structuring, restructuring and securitisation transactions. Adam Blakemore leads the practice group and ‘has exceptional knowledge of tax legislation and how to apply it in practical situations’. ‘A truly outstanding tax lawyer’, he advised a global financial institution on the tax structuring of the first securitisation of marketplace consumer loans in Europe. The London team was also part of a cross-office team that acted on behalf of a certain group of lenders in connection with the €1bn restructuring of The Camaïeu Group.

Clyde & Co LLP has expertise in employment taxation and inward investment and is particularly active in the insurance and real estate sectors. In 2016, David Blumenthal assisted Appleby Westward Group with the tax issues surrounding the client’s acquisition of Gillett’s Callington, which included the acquisition of the target’s 63 stores throughout South West England. Tax department head Ray Smith advised Simec Group on its acquisition of Alcan Aluminium UK, which owns the last smelter to be sold in Rio Tinto’s UK portfolio; indeed, this acquisition also included two hydropower plants, a port and 100,000 acres of estate land. AIG, MetLife and Liberty House Group are also clients.

The London-based tax team at Davis Polk & Wardwell LLP has experience of the tax planning aspects of corporate M&A, private equity and capital markets transactions, and is well-positioned to handle transatlantic transactions. Jonathan Cooklin heads the UK tax department and is instructed by corporates and financial institutions in connection with the tax aspects of international M&A, corporate finance and restructurings. John Paton oversees the firm’s tax practice in Europe and Asia and specialises in US and international tax planning particularly in relation to capital markets transactions. The team has acted for all the well-known global investment banks, such as J.P. Morgan, Citigroup, Morgan Stanley and Credit Suisse.

Dechert LLP’s London tax department ‘couples very strong expertise with a commercial and pragmatic approach’ and has considerable expertise advising investment managers on the tax structuring of transatlantic transactions. Indeed, department head Mark Stapleton has ‘strong understanding of the asset management industry’, but also handles the tax aspects of public and private M&A, real estate acquisitions, structured products and various other corporate and banking transactions. Stapleton provided detailed tax advice to Apollo Global Management in relation to its new global asset management business, which aims to provide investment management services to US and EU CLO and securitisation structures. Daniel Hawthorne is a senior associate in the department.

Dentons offers ‘technical and commercially reliable’ tax advice in connection with M&A, reorganisations, joint venture agreements and funds and real estate transactions. Department head Alex Thomas, who has an active transactional and advisory tax practice, advised John Lewis on the tax provisions of a joint venture agreement with Clipper Logistics. The team has extensive experience in the oil and gas sector and acted for Hurricane Energy on its £74m capital raising and open offer to existing shareholders, for the purpose of developing certain North Sea assets. Another ‘first-class tax lawyer’ in the team, senior associate Suhail Qureshi displays ‘exceptional commercial acumen’ and has been involved in a range of corporate transactions in 2016-2017. Jeremy Cape joined Squire Patton Boggs in 2017, and Andrew Thornton took a position with one of the firm’s underwriter clients.

Goodwin’s tax team is driven by ‘a hands-on, practical’ approach and has enjoyed an expansion of the firm’s London-capabilities, which has exposed it to a broader range of transactional work. Sarah Priestley joined the firm in 2017 from Shearman & Sterling LLP and now heads the London tax team. Ben Eaton has ‘outstanding knowledge of foreign tax systems and is able to use that knowledge to provide multijurisdictional structuring advice’. He has extensive experience in real estate and private equity transactions and is instructed by clients such as Deutsche Asset Management and TA Associates. Laura Charkin advised the UK Green Investment Bank on multiple closings by the UK Green Investment Bank Offshore Wind Fund.

The tax team at Gowling WLG has experience in a wide range of corporate transactions including work in the technology and pharmaceutical sectors, but is especially strong in the investment funds space. Michael Murphy specialises in corporate M&A and capital markets transactions and has particular experience acting for clients in the life sciences sector. National department head Lee Nuttall splits his time between the firm’s Birmingham and London offices and specialises in the tax aspects of private funds transactions, but has also been instructed in advisory roles in stand-alone matters. Elliot Weston joined Hogan Lovells International LLP in 2016.

The corporate tax department at Jones Day has considerable experience of real estate-related transactions, but also handles the tax aspects of the acquisition and disposal of financial assets. Department head Blaise Marin-Curtoud advised Oxenwood Real Estate on the tax issues arising from multiple acquisitions in its logistics portfolio, in addition to incentive arrangements for the founders and management team. Charlotte Sallabank was instructed by the management team of NewDayCards to handle the full-range of corporate tax issues associated with the sale of the business to Cinven and CVC. Newly made partner Anthony Whall specialises in real estate tax and M&A and is instructed by clients such as Euronext and Altium Capital.

Mishcon de Reya LLP carries out a wide range of transactional tax work, but has particular experience of real estate-related tax mandates. Jonathan Legg leads the real estate tax group and acted for Chelfield Partners in relation to the £180m sale of two Central London hotels, which involved the sale of a Luxembourgish holding company to a Danish pension fund. John Skoulding heads the corporate tax department and was instructed by The O’Brien Group to design and manage a corporate demerger, reorganisation and refinancing, and also implemented an employee incentive scheme for the client. Gary Richards has extensive experience of domestic and cross-border tax planning.

With instructions from a variety of multinationals, investment funds and private equity firms, Morgan, Lewis & Bockius UK LLP’s tax department is an integral part of the firm’s UK structured finance and private investment funds teams. The tax group is led by Kate Habershon, who has experience in a range of debt capital markets and fund structuring work for venture capital firms and investment banks. Paul Beausang specialises in real estate-related taxation and the tax aspects of structured finance transactions. Past clients have included Gramercy Property Trust.

Osborne Clarke LLPprovides exceptional advice’ to corporates and funds clients, and with ‘personalised service at out-of-London prices’ the firm provides clients with ‘compelling reasons’ to look beyond the normal City firms for tax advice, according to one source. Michael Bell was instructed by the management team of Odeon & UCI Cinemas Group to handle the international tax structuring of its £921m sale to AMC Theatres. Erika Jupe is advising Solarplicity on the tax aspects of the formation of a group structure incorporating a portfolio of solar PV assets. Tracey Wright is highly recommended. Senior associate Tom Pygall joined from King & Spalding LLP in 2016.

Paul Hastings LLP provides ‘very good advice on complex issues’ and has an ‘excellent understanding of the commercial drivers’ of cross-border corporate and finance transactions. Arun Birla ‘really understands what a client wants’ and has experience in the full gamut of transactional tax work and advisory matters. His recent work has spanned fund formation, securities issuances and M&A, in addition to advising clients such as Credit Suisse on the tax structuring of certain structured products. Associate Jiten Tank assisted Aalto Invest Holding and its owners with its disposal to Man Group. Significant clients include AIG, Filtration Group and DRC Capital Funds.

Pinsent Masons LLP’s transactional tax team has been involved in some enviable mandates in 2016-2017, which have showcased the team’s aptitude in pre-transaction and post-transaction international tax structuring. Eloise Walker is the primary contact in the London transactional tax group and leads the firm’s international tax initiative. Indeed, much of Walker’s work involves tax planning across a number of legal jurisdictions; as an example, she acted for Teva Pharmaceuticals Europe BV on the £603m disposal of its interest in Activas UK and Activas Ireland. Similarly, she advised the shareholders of Skyscanner on its £1.4bn disposal to China’s largest online travel firm, CTrip. Leeds-based John Christian is another key contact in the firm’s UK corporate tax department, and Heather Self has particular experience in international tax planning. The team’s varied client base includes AMC Entertainment Holdings, HSBC and Costain.

Proskauer Rose LLP is known for its ability to ‘manage significant transactions to very tight deadlines’ and has seen a considerably broader range of work following a couple years of expansion in the firm’s UK corporate team. Department head Robert Gaut has ‘exceptional knowledge of funds taxation’ and provides tax advice to a number of very significant investment funds and asset managers in relation to fund formations, closings and investments. The firm’s client base is not limited to funds and asset managers; Gaut also advised Crowe Horwath on the acquisition of the entire issued share capital of BaxterBruce and Instratus. Catherine Sear and London-office head Mary Kuusisto, who is an ‘outstanding’ adviser on US tax issues in the private equity sector, are also recommended.

In 2016, Reed Smith LLP significantly expanded its tax practice with the addition of Gareth Amdor, who was head of tax for the now defunct London office of King & Wood Mallesons. The department has extensive experience of the media, life sciences, private equity, financial services and energy and natural resources sectors. Caspar Fox advised Motif Bio on the tax implications of its dual-listing on NASDAQ and AIM. Consultant Simon Gough is advising Heidrick & Struggles International on withholding tax issues in connection with the client’s in-house cash pooling and netting arrangement with a UK finance company. Senior associate Philippa Michie joined from Ashurst in 2016.

Sullivan & Cromwell LLP’s transatlantic tax group is regularly involved in the US tax aspects of large M&A, and also provides UK tax advice on corporate finance, structured finance, securitisation, capital markets and real estate transactions. Indeed, European counsel Andrew Thomson advised CNH Industrial on the UK tax issues associated with its SEC-registered $600m note issuance. Working between the firm’s London and New York offices, Eric Wang and Ronald Creamer focus on US tax matters and provided supplemental tax structuring advice to Anheuser-Busch InBev following its colossal £79bn acquisition of SABMiller’s outstanding share capital.

Trowers & Hamlins LLP’s tax group is particularly strong in real estate and development projects, especially where there are Middle Eastern or South-east Asian deal-participants that require Islamic-compliant structures. Andrew Sneddon heads the practice group and has been instructed to provide tax advice to clients such as Balfour Beatty Investments, European Islamic Investment Bank, Gatehouse Bank, Apache Capital Partners and various UK local authorities. Michael Surry was recently made partner and has experience of advising public and private bodies on a range of property development and corporate transactions.

Vinson & Elkins RLLP has traditionally been a market leader in the oil and gas space, but its UK tax practice is looking to expand its breadth with the additions of counsel Sara Stewart from Herbert Smith Freehills LLP and senior associate Andrew Callaghan from Travers Smith LLP, the latter of whom has expertise in private equity. Jenny Doak and of counsel Michael Thompson have extensive experience in oil and energy taxation and were instructed by Apache Corporation to specifically handle the tax aspects of its disposal of interest in the Scottish Area Gas Evacuation system and Beryl Pipeline. Other notable clients include Helios Investment Partners and Africa Oil Corp.

Watson Farley & Williams LLP’s tax team has deep sector expertise in energy and infrastructure, and is one of the few UK tax groups with specialism in maritime-related taxation. Richard Stephens heads the tax group and has provided tax structuring advice to BP Pension Fund in relation to multiple transactions in 2016, including two forward funding developments and a London property disposal. In the M&A space, Tom Jarvis acted for DONG Energy in connection with its sale of a 50% stake in a UK offshore wind project and related joint venture agreements. Senior associate Claire Miles joined the team from Macfarlanes LLP.


Tax litigation and investigations

Index of tables

  1. United Kingdom – Leading tax law firms: Tax litigation and investigations
  2. UK - TDH500
  3. Next generation lawyers

UK - TDH500

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Next generation lawyers

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Widely recognised as a leader in this practice area’, Herbert Smith Freehills LLPconsistently provides comprehensive, first-rate advice on highly complex tax litigation matters’. Led by the ‘tremendously experienced’ Heather Gething, the department is regularly involved in high-value and politically salient tax cases. Indeed, in 2016, Gething and Rupert Lewis acted for Bernard Charles Ecclestone in High Court litigation regarding a £1bn tax assessment by HMRC. Also of note, the tax group acted for Telefonica Europe and Telefonica UK on a judicial review of HMRC’s decision to change the way in which the client would be taxed on network services for customers roaming outside of the EU. Gething also represented PacifiCorp in a High Court claim regarding the recovery of SDRT after the statutory time limits for tax reclamation. On the investigations side, Gething assisted Palatium Investment Management with a HMRC investigation into the realisation of taxable gains in connection with the disposal of certain bonds; this matter proceeded to litigation and will be heard before the Court of Appeal. Senior associate Michael Hunt, who is ‘an astounding talent for tax analysis’, and consultant Ross Fraser are also recommended. Additional key clients include UBS Wealth, Bank of Ireland and Centrica.

Joseph Hage Aaronson LLP is considered by some as the ‘pre-eminent firm for tax litigation in London, and, indeed, in the UK more generally’. The group is made-up of ‘phenomenal’ silks, experienced partners and forensic accountants, who have experience of UK and EU tax litigation and particular strength in corporation tax group litigation orders. The ‘technically superb’ Simon Whitehead and Paul Farmer, who is ‘an expert on European tax law’, acted for British American Tobacco in the long-running test case for the FII Group Litigation, which challenged the UK’s dividend tax and advance corporation tax on UK-headquartered multinationals which source profits abroad; the firm’s own Graham Aaronson QC and Tom Beazley QC handled the advocacy in the case. The team is regularly involved in topical and politically-charged tax-related cases and has been instructed by such public figures as David Cameron. Joint founding partner Michael Anderson ‘combines technical acumen and commercial understanding’ and Daniel Margolin QC is another key contact in the tax litigation group. In 2016, the firm welcomed Ray McCann from New Quadrant Partners LLP and also added three chartered accountants to the forensics team. Other significant clients include Marks & Spencer, Prudential Assurance, Europcar and InterContinental Hotels Group.

Pinsent Masons LLP has ‘profound depth of knowledge and unrivalled experience, whether the dispute requires detailed advice on aspects of the tax law or involves major litigation involving tens of millions of pounds’. The team is truly ‘first-class’ and continues to be involved in market-first tax cases. Joint department head Jason Collins is highly regarded in the practice area and is representing BT Pension Scheme on appeal in test case for over 100 of the UK’s largest employers; the case considers the client’s recovery of £2bn of tax credits concerning investments it made into certain UK companies and is the first UK tax case to be heard by the Court of Justice of the European Union (CJEU) since the Brexit referendum. The ‘profoundly experienced’ Ian Hyde is representing Avon Cosmetics in one of the last cases to be referred to the CJEU before the referendum, which concerns VAT levied in relation to one of the client’s brands. Steven Porter was recently made partner and is leading a series of judicial review challenges brought by taxpayers against HMRC regarding payment notices for the clients’ involvement in tax avoidance schemes. Clara Boyd and the ‘tactically savvy’ Stuart Walsh are also key contacts. The department is especially strong in the financial services and energy and infrastructure sectors, which has attracted clients such as Credit Suisse and British Coal.

Slaughter and May’s contentious tax practice works in parallel with the firm’s top-ranked non-contentious tax team to advise clients, irrespective of sector, from the early stages of a tax investigation through to appeals. Steve Edge recently represented Deutsche Bank in the Supreme Court in a case concerning the turning of cash bonuses into a non-monetary form, which could later be turned into money. Sarah Lee helps lead the contentious tax offering and is acting for Mercuria Energy Europe in a High Court case concerning its involvement in highly publicised "missing trader" VAT fraud in the carbon emissions market. Hays, GDF Suez Teesside and Bupa are other clients. Dominic Robertson and Mike Lane have each developed an active tax disputes practice and have been involved in a number of politically-sensitive tax investigations. Gareth Miles and William Watson are also key contacts. In 2016, Richard Jeens and Damian Taylor became partners in the disputes team and Elizabeth Barrett retired.

Though the team at Clifford Chance has undergone considerable personnel changes in 2017, the contentious tax group retained capabilities in VAT and real estate taxation disputes. Indeed, David Saleh specialises in real estate and indirect taxation and is representing Project Blue Limited in a case against HMRC regarding the largest SDLT claim ever disputed for a single property; the firm won at appeal, after which HMRC petitioned the Supreme Court and the facts are such that around 800 other cases are dependent on the outcome of this case. Simon Corzberg focuses on VAT disputes and successfully resolved a HMRC dispute for Cubico Sustainable Investments, which concerned the restriction of VAT recovery resulting from shareholder loans. In 2017, Liesl Fichardt left the firm for Quinn Emanuel Urquhart & Sullivan, LLP, though the team also made multiple junior-level recruits.

Fieldfisher has ‘a strong tax disputes practice, covering both direct tax on the one hand and indirect tax on the other’. It has experience in a range of very high-value tax disputes and has particular specialism in tax cases with criminal and fraud aspects. Department head Hartley Foster is ‘immensely experienced and can anticipate how HMRC will react in litigation’; he is acting in a multimillion-pound MTIC fraud case and is also representing Bratt Auto Contracts and Bratt Auto Services Company in an appeal concerning the recovery of overpaid VAT after the statutory time limit had been passed. George Gillham is ‘extremely good with HMRC negotiations’ and acted in a piece of group litigation regarding the classification of mobility scooters for excise duty purposes. In addition to his civil litigation casework, he has also advised individual clients facing criminal tax issues.

Freshfields Bruckhaus Deringer LLP’s contentious tax practice is headed by Helen Buchanan and has a history of acting for large corporates and central and investment banks. Buchanan has and active contentious and non-contentious tax practice and has been instructed in transfer pricing and diverted profits disputes in addition to cases involving employment tax, capital gains and tax fraud; she has extensive experience in both UK and international proceedings and is also an accredited mediator. Murray Clayson specialises in international taxation transfer pricing and also handles tax disputes.

The contentious tax group at Hogan Lovells International LLP is ‘always very responsive’ and provides ‘strategic and appropriately detailed advice’. It has been strengthened by some significant lateral hires in 2016: real estate tax specialist Elliot Weston joined the team from Gowling WLG, while Graham Poole joined the firm’s London-based subsidiary team as director of economics and transfer pricing, having previously worked in HMRC’s economics department. Practice head Rupert Shiers is highly recommended and recently represented Ensco in relation to a high-value transfer pricing dispute. Lee Squires heads the VAT and indirect tax group and represented Citibank in tax tribunal litigation regarding HMRC’s requirement that the client meet the cost of a VAT fraud committed by other parties; following the team’s success at tribunal, HMRC has petitioned the Court of Appeal. In another standout case, Ruth Grant acted for British American Tobacco in tax tribunal litigation regarding the imposition of tax penalties where HMRC had determined that the company hadn’t done enough to prevent tobacco smuggling into the UK. Other notable clients include Amazon, Ball UK Holdings, Paragon Offshore Group and Aspen Insurance Group.

PricewaterhouseCoopers Legal LLPprovides responsive and client-focused advice in highly complex tax disputes’. As part of a Big 4 network, the team is able to draw on a wide range of expertise to advise across the whole spectrum of contentious tax issues. Department head Mark Whitehouse is acting for a group of litigants including Orange Spain in restitution claims against HMRC concerning the charge of SDRT and stamp duty. David Anderson successfully defended Dollar Financial UK in the first-tier tribunal (FTT) against HMRC’s attempt to claim VAT payments for supplies that were thought to be tax exempt. The ‘indefatigable’ Peter Halford and Holly Rowland are also key contacts.

Quinn Emanuel Urquhart & Sullivan, LLP broke into the tax litigation space this year with the hire of Liesl Fichardt, ‘a supremely experienced international tax litigator’, who previously headed the contentious tax team at Clifford Chance. The firm already had capabilities in domestic tax disputes, but has now expanded its expertise to include cross-border tax treaty litigation. Fichardt is lead international counsel to Acacia Mining Group in two related matters: first, the highest-value tax dispute pending against the Tanzania Revenue Authority, and, second, arbitration proceedings under various bilateral investment treaties; these cases raise fundamental questions as to the tax treatment of foreign-owned operations and investments in Tanzania. Additionally, Fichardt is representing Canary Wharf Group in two tax appeals involving subsidiaries of the client, which concern the congruence of the UK loan relationship regime with the UK generally accepted accounting practices; HMRC has sought to disallow tax deductions of £230m due to its interpretation of the interaction of tax policy and loan relationship rules. Anthony Sinclair and Epaminontas Triantafilou are also contacts in the practice group.

RPC’s contentious tax practice is ‘of a very high quality and covers a range of issues, from tax avoidance, to accelerated payment notices, to EU law’. It has significant capabilities in alternative dispute resolution and has made it a point to recruit practitioners with experience working for HMRC. Led by Adam Craggs, the team handles tax litigation and judicial review, and also has experience in HMRC investigations. In 2016, Craggs has handled cases involving anti-dumping duties, employee incentive schemes and the UK aggregates levy. Recently promoted to legal director, clients have said Robert Waterson is ‘performing at the level of partner’ and handles direct and indirect tax litigation. Clients of the department include major plc’s such as Sports Direct and Lookers, international operators like L’Oreal and pension groups such as Nestlé UK Pension Trust. Senior associate Michelle Sloane joined the team from The Khan Partnership LLP in 2016.

Simmons & Simmons has ‘proven itself to be consistently excellent’ and ‘compares favourably to both Big 4 firms and other law firms’. ‘Excellent tactician and strategist’ Nick Skerrett heads the practice group and is perhaps ‘the pre-eminent litigator in the indirect tax litigation market’. In the group’s recent flagship matter, Skerrett acted on behalf of 20 banks and investment managers on an Indian tax ruling concerning the Indian Income Tax Revenue’s decision to assess foreign investment funds investing in Indian securities to Indian Minimum Alternative Taxation (MAT); the team successfully intervened in the appeal of the MAT decision and is handling individual judicial review proceedings to set aside the Revenue’s assessments. He also acted in group judicial review proceedings regarding the Government’s decision to withdraw a certain exemption from the Climate Change Levy. Darren Oswick specialises in transfer pricing, corporate avoidance and other various corporate-finance taxation. Heather Rowlands is a recommended senior associate in the practice group.

A client of Weil, Gotshal & Manges (London) LLP’s tax disputes department ‘can’t recommend the group highly enough’, which is not surprising given some of its 2016-2017 successes. Jamie Maples and Oliver Walker achieved a landmark success for The Littlewoods Group regarding a long-running overpayment of VAT case, winning at first instance and appeal – decisions that will have consequences for a host of UK taxpayers, and have already spurred new litigation. In another high-profile matter, Walker and Hannah Fields-Lowes represented Ingenious Media in film investment schemes and the tax structuring thereof. The team has also been involved in large, cross-border tax disputes. Other key client of the department include Shop Direct Group, Neon Underwriting and Serpentine Trust.

Known for its ‘professionalism’, Ashurst’s tax practice has ‘a strong and increasing profile’ in the contentious tax space and ‘provides excellent support to clients and counsel, as well as informative expertise on substantive tax issues’. Department head Nicholas Gardner acted for Bookit Limited in tax tribunal litigation regarding a question of exemption from VAT. Simon Swann is ‘very savvy for real estate-related tax litigation’ and has acted for clients such as charity Longridge on the Thames. ‘An excellent communicator’, Alexander Cox has handled VAT litigation for Gala Coral in the Upper-Tier Tribunal. The group also acts for individual clients and Paul Miller is advising Paul Newey in a tax tribunal case regarding HMRC’s demand for VAT and tax penalties in relation to the client’s business, Ocean Finance. Richard Palmer is a consultant with the department and other notable clients include Hastings Insurance Services.

Some clients have rated Baker McKenzie’s tax team as ‘far stronger tax litigators than one might find at the Big 4 firms’; it also regularly competes with Magic Circle firms for tax litigation work. The department acts for a litany of household name clients, and in 2016 Mark Agnew and David Jamieson acted for Coinstar in relation to an appeal regarding the treatment of the client’s VAT. The team has been involved in a number of significant transfer pricing investigations and disputes including a £100m tribunal case in which Kate Alexander acted for Electronic Arts. Nigel Dolman heads the tax disputes team and Mark Bevington is a highly recommended tax adviser in the group. Additional clients include Marriott Inc and a number of well-known online businesses, travel companies and global telecoms providers. Mark Delaney and Jessica Eden, an accredited mediator, are other key contacts in the practice group.

Berwin Leighton Paisner LLP has ‘a growing presence’ in the contentious tax space, with particular expertise in real estate taxation. Its work is not restricted to real estate tax, however; the team is involved in multiple disputes involving the taxation of equipment leasing, the recovery of overpaid VAT, customs and trade duties and the taxation of remuneration schemes. Indeed, Ron Downhill acted for Brain Disorders Research Limited Partnership in a tax avoidance case concerning whether partnerships are trading on a commercial basis. Senior associate Kate Ison is ‘quietly brilliant’ and is building a dedicated tax litigation practice, having been involved in varied high-stakes matters in 2016-2017. Andrew Tuson was promoted to partner in 2016. Alan Sinyor heads the indirect tax group, while Elizabeth Bradley leads the wider, global tax practice. Richard Harbot and Chris Bryant are also key contacts.

The contentious tax group at Eversheds Sutherland (International) LLP specialises in indirect and VAT tax disputes in which it is instructed by investment banks, plc’s and government entities. Giles Salmond heads the practice group and is handling VAT recovery claims for clients such as N Brown Group and Hilton Hotels. In one particularly standout matter, he is acting for MG Rover Group in a £56m VAT claim concerning which corporates entities are allowed to retrospectively recover overpaid VAT; after success at the FTT, the case may be appealed directly to the Supreme Court. The team has also handled disputes regarding issues such as SDLT and US withholding tax. Additional key clients include Capita, the Government Property Unit, Lookers and JSM Construction.

KPMG Law’s contentious tax group is led by specialists from several areas including VAT, personal tax, customs and excise, and criminal tax investigations. The team is headed by the hugely experienced Amanda Brown, who has acted in various courts, covering issues such as landfill tax, VAT, residence disputes and group litigation. Hilary Waters specialises in indirect tax litigation, while Matthew Fleming handles customs and excise issues and Suzie Moore focuses on private client tax disputes. Past clients have included The Open University, Patersons of Greenoakhill and Volkswagen Financial Services. Robert Hartley left for Mishcon de Reya LLP in 2016.

Macfarlanes LLP runs ‘a strategic tax disputes group, which avoids getting bogged down in the technical details’ and has particular expertise in the areas of financial services, funds and trust taxation. The ‘thorough and sensible’ Gideon Sanitt heads the department and was recently promoted to partner; he is defending Royal Mail with respect to some 300 claimants having issued proceedings on the basis that the client had been required to issue VAT invoices for services that should not have been treated as VAT exempt. Sanitt and Simon Nurney are representing a global commodities trader in relation to an assertion by one African country that the client has a permanent establishment in the country and should be taxed in that jurisdiction accordingly. Senior counsel Joanna Constantis ‘never gives in or gives up’. CDC Administration is another key client.

Mishcon de Reya LLP’s tax litigation team works closely alongside the firm’s non-contentious tax group to handle a range of direct and indirect tax disputes, including judicial review. Having joined the team from KPMG Law in 2016, Robert Hartley is involved in a test case concerning the privacy of particular types of financial services entities under HMRC’s power pursuant to an untested piece of legislation. In an example of indirect tax work, Leslie Allen is representing Mercedes-Benz Financial Services UK in litigation concerning the VAT treatment of certain contracts offered by the client to its customers. Dario Garcia specialises in indirect taxes in the financial services sector and is another contact in the department. Finmeccanica Global Services, Coca-Cola and Harrier LLC are among the department’s notable clients.

The tax disputes team at Norton Rose Fulbright is anchored by the firm’s strong non-contentious tax practice and has recently been involved in a range of matters relating to taxation in the financial services, energy and infrastructure sectors. Practice head Dominic Stuttaford is acting for HSBC in multiple group litigation orders concerning the compatibility of certain EU and English laws. Angela Savin has particular expertise in real estate, funds and financial products taxation and is also representing a number of migrant-resident workers in litigation regarding the UK’s taxing rights over income arriving from the clients’ activities in the North Sea. Chris Bates is instructed by a number of financial institutions and a transport and energy group. BMW, G4S plc and Shire Pharmaceuticals Group are among the department’s representative clients.

As a litigation-only law firm, Stewarts Law LLP has been actively involved in the increasingly salient area of tax litigation. The team specialises in bringing group action cases and is acting for high-net-worth individuals in relation to their personal and business taxation issues. Department head David Pickstone is representing over 200 high-net-worths in litigation regarding the Ingenious Media film investment schemes, and the supposed tax benefits in connection with those investments. He is also acting for FCC Environment UK and FCC Recycling UK as defendant and counterclaimant in relation to its available recovery of overpaid VAT and landfill tax. Associate and barrister Lee Ellis is acting with Pickstone for Makro UK in a dispute with HMRC regarding an anti-dumping assessment. SUEZ Environment is another key client.


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