Tax

Tax disputes

In the current context, where the taxation of multinationals has become a matter of public interest and international tax principles are under review, tax administrations have shown their commitment to review and audit corporate tax affairs. This leads to a corresponding increase in controversies and litigation with local tax authorities. Our international tax team is highly specialised and can provide assistance and advice in all of the various stages of the corresponding tax disputes. We advise regularly on tax audits, information requests, settlement of tax claims and subsequent litigations, both at the local level and before international courts. The potential reputational consequences, which issues of this nature may entail for our clients, require maximum levels of technical expertise and also a deep understanding of the corporate governance aspects of our clients’ business.

Transfer pricing disputes are becoming highly specialised, and we are developing teams in each jurisdiction to provide advice in those sectors where the firm is more active, such as digital business, healthcare or retail. We have also specialised teams in the fields of cross-border indirect taxation, VAT and customs. We are also very active in the discussion and negotiation of Advance Pricing Arrangements in different jurisdictions and have agreed on multi-jurisdictional innovative transfer pricing schemes. 

 

Experience


Healthcare corporation

Coordinated the tax investigations and audits of a publicly traded healthcare corporation, including competent authority settlement with consequences in Spain, US, France, Germany and Italy.

US-listed entity

Advised on an international tax arbitration before ICSID against a capital gains exit tax liability claimed by a local tax authority.

Multinational group

Advised on Advance Pricing Arrangements, covering patent box and cross-border transfer pricing global schemes, for a multinational group, specialised in fashion retail.

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