/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/2024-12-18-20-07-15-265-67632b733e67bad811f56678.png)
We are continuing to see a significant number of large-scale tax investigations and disputes internationally, and with governments across...
Freshfields Risk & Compliance
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/2024-10-31-18-21-50-051-6723cabe063041cc69f36eb0.png)
In the first Budget delivered by the Labour Party since 2010 (and the first given by a female Chancellor since the role came into...
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,...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/2024-06-21-11-39-34-804-66756676cf2af941d9a11203.png)
There are, of course, an infinite number of things that can prompt a tax investigation or audit – but within that plethora of...
/Passle/5832ca6d3d94760e8057a1b6/SearchServiceImages/2024-05-08-13-40-12-906-663b80bc6f5d7d6429e4878a.jpg)
The Court of Appeal has confirmed that the loan relationship unallowable purpose rule in section 441 CTA 2009 applies to deny interest...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/2024-04-16-13-40-47-806-661e7fdf4025ff662f69bcf8.png)
Bringing a contractual claim following the successful conclusion of an M&A transaction is sometimes unavoidable. It is important to...
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...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/63359ea2f636ea0e3436724f/2023-12-13-09-48-17-211-65797de1174e5f79fc5ad631.png)
Back in October, the global Freshfields Tax team published the Tax investigations and disputes across borders guide which, among other...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/59283cdeb00e8004c8062c57/2023-12-07-16-54-56-768-6571f8e0bc7fe5820005dc9c.png)
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...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/63359ea2f636ea0e3436724f/2023-11-27-13-42-47-957-65649cd78f2529df401c63c6.png)
Corporates have long been exposed to the risk of potential criminal tax liability in certain jurisdictions – Italy, for example, where...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/63359ea2f636ea0e3436724f/2023-11-20-16-54-04-539-655b8f2c4a0d511b80c3f67f.png)
As noted in the German section of our Tax investigations and disputes across borders guide, tackling tax avoidance has been a major focus...
/Passle/5832ca6d3d94760e8057a1b6/MediaLibrary/Images/63359ea2f636ea0e3436724f/2023-11-20-14-50-17-444-655b72294a0d511b80c39e53.png)
Taxpayers may seek to reach an out-of-court settlement with a tax authority for various reasons, including reaching a swift(er)...