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 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)...
16 Nov, 2023 2022 MAP statistics: what do they tell us? By Sarah Bond Laura Western Earlier this week, the OECD released its annual set of statistics on the use of the mutual agreement procedure (MAP) in 2022. According...
14 Nov, 2023 The Economic Crime and Corporate Transparency Act 2023: the practical implications from a tax perspective By Sarah Bond Laura Western As our colleagues have discussed here, here and here , the recent enactment of the Economic Crime and Corporate Transparency Act 2023...
08 Nov, 2023 ESG and tax transparency: the next frontier of tax disputes? By Sarah Bond Alison Dickie Laura Western The importance of environmental, social and governance (ESG) issues to businesses cannot be underestimated, with investors, lenders,...
06 Nov, 2023 VAT litigation in the EU: the role of international agreements By Katharina Kubik Annika Streicher As noted in our Tax investigations and disputes across borders guide, issues related to VAT are a common source of tax litigation in many...
26 Oct, 2023 UK corporate crime reform: two major changes impacting how companies may be held liable for fraud and other economic crimes By Matthew Bruce Ben Morgan Ali Sallaway Laura Feldman +1 more... Show less The UK Government has today introduced the Economic Crime and Corporate Transparency Act (the “Act”) to deliver wide-ranging reforms to...