Legal advice for all stages of a tax dispute

Understanding what tax avoidance is, what is the "right tax" - and what is not – is essential for any business. New laws have led to greater scrutiny of whether businesses are paying the right taxes in the right jurisdictions.

Tax authorities often now pursue businesses for tax that would not have been pursued a few years ago. In some cases, domestic governments have granted tax authorities significant new powers to demand information and collect tax even before it is shown to be due. They may also require corporations to police other taxpayers.

How we can help you

Our Tax Disputes team has a formidable track record of resolving tax disputes. We can provide assistance and advice at all stages of a dispute, whether at a local or international level.

Our lawyers regularly advise on:

  • tax audits
  • investigations
  • information requests
  • settlement of tax claims and subsequent litigation
  • mutual agreement procedures
  • negotiating on advance pricing agreements
  • transfer pricing disputes
  • alternative dispute resolution, including international arbitration

Where litigation is necessary, we regularly advise on taking tax disputes to the tax tribunal and courts. 

This is a tightly-focused team, able to deliver in relation to tax disputes and advisory matters across all taxes. Great at collaborating and innovative in relation in particular to disputes work and Alternative Dispute Resolution.

Tax litigation and investigations client, Legal 500

Our tax disputes lawyers

With specialists across Europe, we work closely with other teams at Osborne Clarke to make sure that all aspects of your dispute are covered. We work on both domestic and cross-jurisdictional matters.

Our team acts for a diverse mix of companies, businesses, funds, financial institutions and high-profile individuals across industry sectors. We have extensive experience helping clients through the international tax minefield and adding value at each step of the way.
 

Experience

Major international bank

Acting for a major international bank on settling a dispute as to the application of the relevant double tax treaty to UK group losses involving potential tax losses of over £100m and associated penalties.

Senior executive incentive scheme

Acting for a listed company on HMRC's investigation into a senior executive incentive scheme involving board level governance issues and enforcement of tax indemnities given by participants for the PAYE and National Insurance that would be payable.

Cross-border HMRC information requests

Acting for a digital services provider in connection with wide ranging cross-border HMRC information requests

Internal tax investigation

Acting for UK property group on an internal investigation into prior tax compliance history and potential VAT fraud

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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