The Profit Diversion Compliance Facility: further wave of nudge letters
In 2019, HMRC announced the introduction of a “Profit Diversion Compliance Facility” (PDCF). In very basic terms, the PDCF is targeted at...
Helen leads the firm’s tax disputes practice, advising clients on complex UK and international tax disputes across all sectors.
Her current caseload spans diverted profits tax, transfer pricing and valuation disputes, permanent establishment and controlled foreign company (CFC) issues, employment taxes (including off-payroll working), capital gains and transfer taxes, VAT and tax fraud.
She has extensive UK and international litigation experience and, as a CEDR-accredited mediator, also has a strong track record of resolving cases out of court.
Alongside her contentious practice, Helen advises on a wide range of corporate and finance transactions, including M&A, joint ventures, securitisations, leveraged finance, debt restructurings and corporate reorganisations.
Her sector experience includes energy and natural resources, infrastructure, TMT, pharmaceuticals and banking, and she heads the London office's energy tax practice.
She is ranked in Band 1 for contentious tax by Chambers & Partners and is listed as a leading individual by the Legal 500.
In 2019, HMRC announced the introduction of a “Profit Diversion Compliance Facility” (PDCF). In very basic terms, the PDCF is targeted at...
An arbitral tribunal has unanimously held that India’s imposition of a US$2.7bn tax on Vodafone, which includes more than US$1bn in...
As many potentially-affected UK multinationals are well aware, there is an ongoing EU state aid investigation into the UK’s controlled...
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