19 Dec, 2024 Tax investigations and disputes across borders guide 2025 By Laura Western We are continuing to see a significant number of large-scale tax investigations and disputes internationally, and with governments across...
31 Oct, 2024 Autumn Budget 2024: delivering difficult decisions By Alison Dickie Laura Western In the first Budget delivered by the Labour Party since 2010 (and the first given by a female Chancellor since the role came into...
27 Sep, 2024 Privilege in the context of European tax investigations: Court of Justice confirms tax advice is privileged By Helen Buchanan Laura Western Almost all corporate taxpayers will have sought the advice of tax lawyers at one time or another – be it in the context of a transaction,...
21 Jun, 2024 Workforce-related tax investigations: watch out for your workers By Helen Buchanan Philipp Redeker Cyril Valentin Laura Western Louis-Antoine Jacquet +2 more... Show less There are, of course, an infinite number of things that can prompt a tax investigation or audit – but within that plethora of...
08 May, 2024 A Kwik decision from the Court of Appeal in the latest ‘unallowable purposes’ case By Helen Buchanan The Court of Appeal has confirmed that the loan relationship unallowable purpose rule in section 441 CTA 2009 applies to deny interest...
16 Apr, 2024 Tax Indemnity Claims: Complying With the Notice Provisions in ‘Full-Recourse’ and ‘W&I-Backed’ M&A Deals By Emily Szasz Laura Western Bringing a contractual claim following the successful conclusion of an M&A transaction is sometimes unavoidable. It is important to...
20 Feb, 2024 Limitation: when does the clock start on date of knowledge? A case note on BAT Industries Plc & Ors v Inland Revenue & Anor [2024] EWHC 195 (Ch) By Emma Probyn Jack Helyar At a Glance The High Court has handed down its judgment in BAT Industries Plc & Ors v Inland Revenue & Anor [2024] EWHC 195 (Ch), which...
13 Dec, 2023 Trends in tax disputes: what should businesses be aware of? By Laura Western Back in October, the global Freshfields Tax team published the Tax investigations and disputes across borders guide which, among other...
07 Dec, 2023 German VAT law and ECJ rulings: how much VAT is due if invoices contain an incorrect overstatement? By Dr. Tanja Walter-Yadegardjam Hendrik Menzel EU Member States are required to transpose Council Directive 200/112/EC of 28 November 2006 on the common system of value added tax (the...
28 Nov, 2023 The increasing risk to corporate groups of criminal tax investigations across Europe By Sarah Bond Laura Western Corporates have long been exposed to the risk of potential criminal tax liability in certain jurisdictions – Italy, for example, where...
22 Nov, 2023 Unravelling the complexities of German transfer pricing audits By Philipp Redeker Viktoria von Abel As noted in the German section of our Tax investigations and disputes across borders guide, tackling tax avoidance has been a major focus...
20 Nov, 2023 Out-of-court settlements with tax authorities: the position in France By Cyril Valentin Juliette Brasart Taxpayers may seek to reach an out-of-court settlement with a tax authority for various reasons, including reaching a swift(er)...