Sep 27, 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,...
Jun 21, 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...
May 08, 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...
Apr 16, 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...
Feb 20, 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...
Dec 13, 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...
Dec 07, 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...
Nov 28, 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...
Nov 22, 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...
Nov 20, 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)...
Nov 16, 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...
Nov 14, 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...