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The comprehensive guide to the world's leading tax firms

Allen & Overy's tax department is particularly well regarded in M&A, cross-border structuring and capital markets matters though it is also capable in indirect tax and tax litigation. The presence of Stephen Fiamma as the head of the firm's London-based ... [more]

Allen & Overy's tax department is particularly well regarded in M&A, cross-border structuring and capital markets matters though it is also capable in indirect tax and tax litigation. The presence of Stephen Fiamma as the head of the firm's London-based US tax group provides the firm with significant transatlantic capacity in tax matters. Former big four partner Peter Mendham acts as a VAT consultant for the tax practice and ensures the team has a comprehensive ability in VAT matters. With tax departments in more than 20 offices worldwide, the firm is well placed to provide a comprehensive tax practice for outbound as well as inbound investment.

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The tax team at Clifford Chance was involved in one of the largest M&A deals in 2010 when they advised both International Power and GDF Suez on their merger in a transaction worth £18 billion ($30 billion). David Harkness, the firm's global head of tax, ... [more]

The tax team at Clifford Chance was involved in one of the largest M&A deals in 2010 when they advised both International Power and GDF Suez on their merger in a transaction worth £18 billion ($30 billion). David Harkness, the firm's global head of tax, and partner Nick Mace led the team responsible for implementing a tax efficient structure for pre-completion internal reorganisation, inter-group financing and a cash-box structure used to fund a special dividend to International Power shareholders.

Mace also coordinated a transatlantic team acting for the syndication of underwriters in the largest ever IPO in the UK by commodities company Glencore. Their work for Citigroup, Morgan Stanley and Credit Suisse in the matter marked the first ever simultaneous listing on the London Stock Exchange and the Hong Kong Stock Exchange. The multi-jurisdictional aspects in not only the IPO but also of the underwriters' businesses required detailed management of cross-border tax issues. Clifford Chance is well placed to deal with such issues, having US tax experts in its London office in a department with 12 partners and more than 30 other fee earners. With a tax consultant now in Beijing, the firm has consolidated its ability to advise on international tax issues, especially with regard to inbound and outbound Asian investments. Michael Brosnahan is highly respected by competitors for his structuring work, which is said to be creative and innovative. This was important in his work for Macquarie Infrastructure Group last year on the tax implications of the group's demerger and internationalisation of their management. The group was split into two separate listed entities with Macquarie retaining direct control of one of the companies, requiring careful use of structures to limit tax charges.

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Deloitte's UK tax team provides services to clients across a full range of tax matters, including tax controversy. The tax dispute resolution practice that was created after Fiona Walkinshaw's arrival in 2009 has been improved this year by the firm's ... [more]

Deloitte's UK tax team provides services to clients across a full range of tax matters, including tax controversy. The tax dispute resolution practice that was created after Fiona Walkinshaw's arrival in 2009 has been improved this year by the firm's transaction implementation check (TIC) system. This service assists clients by using technology to streamline and catalogue the documentation involved in transactions. The idea is to enable companies to provide a full response and eliminate any gaps in documentation if the tax treatment of a transaction is challenged by HMRC after the event. Recent highlights for the firm's tax controversy practice include a case concerning VAT refunds for a client in the gambling sector which went to the Court of Appeal. At first instance, the court ruled that HMRC's differing VAT charges for certain games run by the company were incompatible with ECJ case law on VAT. This decision was upheld in the Court of Appeal in late 2010 and is expected to mark an important precedent for the betting and gaming industry. Anbreen Khan, who is identified by peers for his indirect tax expertise, coordinated the technical VAT elements of the case. Deloitte also advised on the IPO of a private equity backed group and substantially restructured the group before the offering so as maximise the group's value on floatation. Before Deloitte's involvement, the majority of the group's debt was held by its Luxembourg entity despite an absence of provisions allowing company to offset debt against taxable gains. Profits relating to its most lucrative intellectual property rights were also taxed in Japan, which had a 41% tax rate on such income. By restructuring the group's operation, the firm was able to significantly reduce the rate of effective tax for the company prior to its IPO.

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John Dixon leads the tax practice of Ernst & Young which provides clients with comprehensive services across a full range of tax issues, though competitors note that its international tax and cross-border structuring services are particularly strong. ... [more]

John Dixon leads the tax practice of Ernst & Young which provides clients with comprehensive services across a full range of tax issues, though competitors note that its international tax and cross-border structuring services are particularly strong. Matthew Mealy heads the international tax services team and is noted by his peers to be a highly able practitioner. The firm is also well regarded for transfer pricing and competitors recommend John Hobster for his ability in that area. Three partners have joined the tax practice this year and 15 advisers have been promoted to partner level from within the department, providing the firm with 155 partners and 2200 fee earners. The firm notes that there has been a rise in demand across all of its service line for cross-border advice as both inbound and outbound investments have picked up. This may be due to the fact that a significant proportion of the firm's client base is made up of multinational companies. Significant work for the firm this year has included assisting global companies with relocation of business activity to the UK to take advantage of the proposed tax reforms designed to make the UK more attractive to international investment. This work has included headquarter redomicilisations to the UK and the relocation of intellectual property development for companies involved in scientific innovation. According to Mealy, such work is indicative of the impact the changes to the corporate tax regime will have for the UK.

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Sarah Falk leads Freshfields Bruckhaus Deringer's tax practice which comprises 12 partners and 26 further fee earners. The firm's clients include noteworthy British companies such as Rolls Royce and Westfield Shopping Towns and banks such as Barclays ... [more]

Sarah Falk leads Freshfields Bruckhaus Deringer's tax practice which comprises 12 partners and 26 further fee earners. The firm's clients include noteworthy British companies such as Rolls Royce and Westfield Shopping Towns and banks such as Barclays Capital, JP Morgan and many other financial sector companies. The firm is singled out alongside Slaughter & May as one of the leading law firms when it comes to tax by other tax advisers in the market. Competitors have identified David Taylor for his corporate tax work and this area represents a real strength for the firm. One of his peers commented that "though Freshfields has a good team across the board, he is particularly good. He is not only a smart guy, but very pleasant to work with".

Work for the firm this year has included advising Petrofac on their purchase of a 15% stake in Seven Energy as part of an agreement to help that company develop its production, processing and transportation assets. Under the agreement, Petrofac's stake may be adjusted either upwards or downwards depending on Seven Energy's performance and as such Freshfields had to structure the deal to minimise tax consequences in either case. Restructuring and refinancing characterised the matter completed for HSBC Rail UK in respect of the sale of their rail leasing business Eversholt Rail. The consortium of infrastructure funds making the purchase provided consideration in both bonds and cash, requiring Freshfields' close scrutiny of tax issues for the seller. Freshfields are confident that increasing activity in M&A and capital markets at the start of 2011 will ensure their tax department is even more active over the next year, as they note that they are still involved in a number of insolvency and restructuring matters.

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Linklaters has experienced a resurgence of work related to M&A and equity raisings this year. Dominic Winter led the team that advised J.P Morgan on the £700 million ($1.12 billion) IPO of Vallar plc, a listed acquisition vehicle in the mining sector. ... [more]

Linklaters has experienced a resurgence of work related to M&A and equity raisings this year. Dominic Winter led the team that advised J.P Morgan on the £700 million ($1.12 billion) IPO of Vallar plc, a listed acquisition vehicle in the mining sector. This was one of the largest acquisition vehicle listings on the London market to date and necessitated advice on international tax structuring and implementation. The practice also advised GDF Suez on their €20.2 billion ($28.1 billion) reverse takeover of International Power. Mark Kingstone and Lucy Jones conducted the team to create a tax efficient structure for a pre-completion internal reorganisation, inter-group financing and the cash-box structure utilised to fund a special dividend to International Power shareholders. The firm's advisory role in BP's £4.5 billion ($7.19 billion) financing of its operations in Azerbaijan and Angola illustrates its credentials where complex corporate structures are concerned. Loan facilities are to be provided to BP Angolan and BP Caspian entities directly but are to be repaid out of the proceeds paid to each company's special purpose vehicle (SPV) by BP Oil International for crude oil in a back-to-back arrangement. Each facility is secured over the assets of the SPV, including commercial contracts and accounts. This structure prevents any liability under the loan agreements attaching to BP plc directly, significantly complicating tax arrangements in the process. Contentious tax represents a strong point for the firm, with further work being done for BP in pursuit of a £300m refund from HMRC in respect of stamp duty reserve tax. Department head Yash Rupal, who is highly rated by his rivals, led the firm in advising Vodafone in their challenge of HMRC's proposed investigation of tax affairs. The case involved substantial coordination between the litigation and tax practices to obtain an early reference to the European Court of Justice in 2007. The team was heavily involved negotiation with HMRC that resulted in settlement of the issue in July 2010.

PwC provides clients with a full range of tax services but it has a particularly well regarded M&A practice, with Mark Wardle noted by peers for his ability in that area. The firm also has significant capacity in transfer pricing, with 10 partners and more than 100 other fee earners being specialists in that area. The firm this year advised a multinational company on their group royalty strategy relating to its intellectual property. The team involved ensured that the strategy was consistent with the arm's-length principle throughout as well as the OECD principals in Europe and specifications particular to the US. The firm also implemented a model whereby the royalties paid by operating companies were split between the group's brand management entity and its trademark owning entities. In doing so, the firm optimised the group's tax affairs and ensured efficient compliance with applicable transfer pricing regulations.

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Several practitioners in the tax team at Slaughter and May, led by Sara Luder, are highly rated by their competitors. Luder herself is well regarded by other advisers for her capital markets and financial products expertise. Tony Beare receives plaudits ... [more]

Several practitioners in the tax team at Slaughter and May, led by Sara Luder, are highly rated by their competitors. Luder herself is well regarded by other advisers for her capital markets and financial products expertise. Tony Beare receives plaudits from a significant number of advisers for his intelligence, knowledge and ability to collaborate. A partner at a firm who had worked with Beare on a number of deals commented that, "his knowledge is impressive and he's a good guy who is really easy to work with." Beare leads the tax efficient financing team that works in conjunction with the firm's financing team. Similarly, Steve Edge is noted for his capital markets and corporate tax work. The firm's capital markets expertise was central to advice given to Royal Dutch Shell on their issue of scrip dividends in late 2010. This was complicated by the fact that the company is a UK plc but resident in the Netherlands for tax purposes. The company issued two classes of shares that will provide dividends from a Dutch subsidiary and UK subsidiary respectively. However, to circumvent negative tax treatment only the shares that would give dividends from the Dutch subsidiary were issued as scrip dividends. Importantly, as a result of the company's residence outside the UK those shares issued as scrip dividends are to be treated as a capital receipt for those shareholders resident in the UK and so will not be considered taxable income. Since many of the group's employees are also shareholders, the firm obtained clearance of their analysis from HMRC due to the imprecision of relevant legislation.

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Herbert Smith's tax practice is led by Bradley Phillips and provides services to clients in a full range of tax services. Its ability in Europe is particularly pronounced as a result of its alliance with Gleiss Lutz in Germany and Stibbe in the Netherlands. ... [more]

Herbert Smith's tax practice is led by Bradley Phillips and provides services to clients in a full range of tax services. Its ability in Europe is particularly pronounced as a result of its alliance with Gleiss Lutz in Germany and Stibbe in the Netherlands. The firm is particularly distinguished in M&A and tax controversy matters and is well reputed in investment funds, energy, outsourcing, asset management, real estate and corporate restructuring matters. Notable work for the firm this year included the advice provided to energy company EdF for the tax issues arising from its divestment of its distribution company in the UK. As the group is based in France, the team involved had to consider various cross-border tax issues and the tax implications of the transaction in France. The firm also devised a tax efficient structure for the proposed merger between food producers Northern Foods and Greencore, which was later aborted, requiring close attention to cross border structuring due to the international dimensions of both those companies. Neil Warriner has also been active in real estate matters this year. In late 2010, he advised on a £1.8 billion ($2.99 billion) joint venture between Crown Estates and the Norwegian Government Pension Fund that is to run the Crown Estate's Regent Street portfolio. Warriner also advised on the 'cheesegrater' skyscraper development on Leadenhall Street which posed particular issues with VAT.

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KPMG's UK tax team is led by Alastair McLeish and the firm is well regarded in a wide range of tax issues. This year partner Julie Hughff was awarded one of HMRC's inaugural tax transparency awards. This comes after Anneli Collins' efforts to improve ... [more]

KPMG's UK tax team is led by Alastair McLeish and the firm is well regarded in a wide range of tax issues. This year partner Julie Hughff was awarded one of HMRC's inaugural tax transparency awards. This comes after Anneli Collins' efforts to improve the firm's relations with HMRC when she was appointed as head of tax policy last year, as Hughff was recognised for encouraging clients to engage in an open dialogue with HMRC about their tax affairs.

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The tax team at Macfarlanes is in a good position to exercise its strengths in tax structuring and restructuring work. Partner Damian Crossley noted that the team has been moving towards more technical areas of tax in the last five years and though the ... [more]

The tax team at Macfarlanes is in a good position to exercise its strengths in tax structuring and restructuring work. Partner Damian Crossley noted that the team has been moving towards more technical areas of tax in the last five years and though the firm is capable in corporate support work, such matters represent only 20% of the department's work. The majority of work undertaken by the department relates to fund structuring work which often has cross-border elements. Its strength in this area is illustrated in recent work completed for Haymarket Financial. Having acted for the management in the establishment of fund, the firm is now retained as the fund's structuring adviser. In June 2010, the firm advised the fund on its €400 million ($576.44 million) joint fundraising with the Australia Future Fund ensuring that a tax efficient structure was used that accommodated both parties' commercial requirements. The firm also aided Montagu in establishing their fourth €2.5 billion pan-European private equity fund. The fund spans Poland, Germany, France and the UK and necessitated careful structuring and attention to cross border tax issues by Mark Baldwin's team. Andrew Loan is leading the firm's team involved in the Four Seasons Health Care group's £800 million debt restructuring. The matter is highly complicated due to the group's previous debt restructuring in 2009. The firm's notable clients include the Virgin group, Pernod Ricard and Legal and General in addition to the private equity firms and funds the firm has worked for this year. The tax department has developed a strong reputation among competitors under department head Ashley Greenbank. Many practitioners have commented on the firm's expertise in fund structuring in particular and one adviser from the big four commented that Macfarlanes are often rivals when pitching for structuring work.

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The global head of Norton Rose's tax group, Louise Higginbottom, also leads its UK tax practice which is particularly strong in corporate finance, technology, investment funds and real estate. This firm also has a well regarded litigation team led by ... [more]

The global head of Norton Rose's tax group, Louise Higginbottom, also leads its UK tax practice which is particularly strong in corporate finance, technology, investment funds and real estate. This firm also has a well regarded litigation team led by partner Charles Evans. Competitors identify John Challoner as one of the team's standout performers and he is highly rated for both his corporate tax work and capital markets expertise. One of his peers commented: "He is simply fantastic to work with. He finds solutions that are agreeable for both sides and he is not interested in point scoring." The firm prides itself on being at the forefront of tax developments and highlights its work in Islamic finance matters as indicative of its flexibility. In response to rising demand for Islamic compliant financial products, the firm noted that restrictions were inadvertently imposed on their use by tax constraints. The firm consulted with HM Treasury and HMRC to circumvent the issues and ensure that UK tax law accommodated Islamic as well as mainstream financial products.

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Alvarez & Marsal Taxand seek to provide clients with an alternative to the big four accounting firms where partners are more involved in the day-to-day practice of the firm. This philosophy has meant that the firm still has a fee-earner to partner ratio ... [more]

Alvarez & Marsal Taxand seek to provide clients with an alternative to the big four accounting firms where partners are more involved in the day-to-day practice of the firm. This philosophy has meant that the firm still has a fee-earner to partner ratio of less than four to one. This year, the firm has strengthened its practice at partner level with the addition of two former KPMG partners in Tom McFarlane and Stephen Machin. The firm offers clients a full range of tax services and even provides companies with the option to add its partners as tax directors where significant changes to tax practices and affairs are required. Recently, a partner of the firm was added to the board of an inbound Japanese company seeking help to prepare for the impending changes in the CFC regime. The firm is noted for its ability in structuring matters and international tax and this is reflected in the number of private equity firms relying on its team for tax advice. Ian Fleming recently led the team that advised Francisco Partners on its public to private acquisition of IT company smartFOCUS. The transaction involved a cross-border merger to integrate the company into one of the private equity firms existing groups, requiring the firm to ensure an effective structure was in place and international tax issues did not complicate matters. Other private equity firms that have sought the firm's advice include 3i and First Reserve. Kevin Hindley, who peers rate highly for international tax and structuring work, says that much of his work this year has involved post-merger integration and structuring. His role in advising a FTSE 250 technology company on post-merger integration pursuant to a series of acquisitions exemplifies this.

The firm has continued its involvement in the development of tax policy. Last year, Machin advised the UK Conservative party on its tax policy and the firm has this year consulted the Greek government on making significant changes to its tax regime following its well publicised financial difficulty.

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Ashurst's tax department is led by John Watson in London. The firm has a strong network of tax professionals across Europe in particular but it also has tax specialists present in New York. The firm is noted for its strength in capital markets work in ... [more]

Ashurst's tax department is led by John Watson in London. The firm has a strong network of tax professionals across Europe in particular but it also has tax specialists present in New York. The firm is noted for its strength in capital markets work in particular, though also offers services in corporate tax, M&A, cross-border tax planning, restructuring, real estate, investment funds and contentious tax. Highlights of the firm's tax work this year included advising the senior management of software company Openbet Technologies on its buyout by private equity firm Vitruvian Partners. The firm advised the management on all aspects of the transaction, but Watson coordinated the tax issues throughout. Richard Palmer led the tax team involved in advising Real Estate Opportunities on its proposed £1.96 billion debt restructuring. The restructuring is to involve the transfer of Battersea Power Station to a new holding company and £437 million of the group's debt is to be converted into equity in the new holding company. The restructuring has been facilitated by agreement with the Lloyds Banking Group and NAMA as well as Oriental Property. Capital markets matters have also been important for the firm this year and Palmer dealt with the tax issues when the firm advised Jefferies International on its role as nominated adviser (Nomad) to oil and gas exploration company 3Legs Resources in its initial public offering on AIM. As Nomad, Jefferies International will be guiding 3Legs on the formalities the company will need to comply with to be listed on AIM. As such, Palmer had to ensure that they were able to advise appropriately on the tax considerations for the company.

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Alex Chadwick acts as the head of Baker & McKenzie's corporate tax group in London and is also a member of the firm's Europe Tax Transactions Steering Committee. The firm is capable across all areas of tax, but is noted for its transfer pricing services ... [more]

Alex Chadwick acts as the head of Baker & McKenzie's corporate tax group in London and is also a member of the firm's Europe Tax Transactions Steering Committee. The firm is capable across all areas of tax, but is noted for its transfer pricing services in particular and the firm was one of the first to employ economists to help provide clients with transfer pricing advice. Recent work for the firm in that area includes both assisting companies challenged by HMRC in transfer pricing and advising companies on all aspects of transfer pricing strategy and compliance. The firm represented two global groups based in the UK in disputes with the tax authorities this year. One case has been included in HMRC's sizeable pilot dispute resolution scheme that involves external mediators in an effort to resolve such disputes more quickly. Counsel James Kennedy advised a multinational plastics company on a global review of its intellectual property ownership and development and its impact on transfer pricing. Since intellectual property carries significant value in the plastics industry, the tax treatment and transfer pricing affairs of the group's intellectual property has significant bearing on its profits. The firm has also been active in M&A this year and advised a New York Stock Exchange listed manufacturing and technology company on its acquisition of a secure power supplier in the UK. Partner Geoffrey Kay led the team that provided tax planning advice to the company to ensure that the most tax efficient structure was used for both the acquisition and the newly expanded group's tax affairs.

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Berwin Leighton Paisner's tax practice has different partners leading different areas of the practice. Michael Wistow acts as head of tax while John Overs oversees the corporate tax practice. The firm is capable in a number of tax disciplines but has ... [more]

Berwin Leighton Paisner's tax practice has different partners leading different areas of the practice. Michael Wistow acts as head of tax while John Overs oversees the corporate tax practice. The firm is capable in a number of tax disciplines but has particular focus on capital markets, corporate financing, fund and investment structuring and real estate. The firm has this year built on the work done for Tesco last year and handled the company's £5 billion programme to release value from its real estate portfolio. This has involved a number of off balance sheet joint ventures and sale and leaseback arrangements, each of which has required close attention to the corporate structures involved. The financing expertise of the firm was evident in Allied London Properties' construction financing and re-financing of the Civil Justice Centre in Manchester. The refinancing involved a securitisation of assets in which tax issues were an important feature for the firm to consider. While the firm recruited heavily in previous years and is strong in several areas of tax, competitors have noted that the tax team has not been prominent in the UK tax market of late.

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DLA Piper is known for its ability in tax controversy matters and has a distinct department dealing with tax investigations and disputes in which Richard Smyth and Neil Gerrard are partners. The addition of Derek Medlam, a former PwC partner, has bolstered ... [more]

DLA Piper is known for its ability in tax controversy matters and has a distinct department dealing with tax investigations and disputes in which Richard Smyth and Neil Gerrard are partners. The addition of Derek Medlam, a former PwC partner, has bolstered this part of the department given his substantial experience and knowledge of regulatory compliance issues. The firm has been developing its non-contentious tax practice though and now has six partners across the UK who handle tax matters under department leader Stephen Hoyle. The firm has built an impressive group of clients who rely on the team for tax advice including Barclays Ventures, Boots, HBOS, HSBC, Tiger Properties and Warner Bros. The firm has benefitted from the pickup in private equity activity and has advised Barclays Ventures on the best structures for its private equity investments and the tax implications of its ventures. Tax controversy and dispute resolution is a real strength of the practice though and former barrister Simon Airey is well equipped to represent clients in litigious matters and has experience of dealing with the Securities and Exchange Commission in the US as well as HMRC. In 2010, Robert Hartley was involved in the Weightwatchers v Revenue and Customs case which is expected to set a precedent on when employees will be defined as self employed for tax purposes.

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Karen Hughes leads Hogan Lovells's UK tax practice with four further partners and 15 other fee earners comprising her team. The firm has a good reputation across a range of corporate tax issues, with Greg Sinfield singled out by his competitors for his ... [more]

Karen Hughes leads Hogan Lovells's UK tax practice with four further partners and 15 other fee earners comprising her team. The firm has a good reputation across a range of corporate tax issues, with Greg Sinfield singled out by his competitors for his work in indirect tax. Sinfield's expertise in VAT was crucial to Loyalty Management UK's appeal to the ECJ over tax imposed on the company in relation to its supply of the Nectar cards reward scheme, which has been referred back to the Supreme Court and is awaiting trial. This firm has also been engaged in transactional work with Phillip Gershuny leading the tax team involved in the sale of EMI music. The transaction involved the acquisition of insolvent record company EMI by Citibank and necessitated Citibank writing off some £2.2billion in loans previously made to EMI. Hogan Lovells advised the administrators on particular tax issues arising from EMI's insolvency. The firm also advised Henderson Global Investors on the foundation of a new fund to invest in offices in central London. European, British and Canadian investors all participated in a partnership structure with offshore feeder vehicles to accommodate the various investors' profiles. Hogan Lovells was responsible for developing and advising on this structure to accommodate domestic and international requirements in such a way as to minimise their tax liability.

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Latham & Watkins's UK tax team is part of the firm's European tax practice, of which London partner Daniel Friel is vice chairman. Much of the firm's work is pan-European in scope and it emphasises the depth of its practice internationally as a distinguishing ... [more]

Latham & Watkins's UK tax team is part of the firm's European tax practice, of which London partner Daniel Friel is vice chairman. Much of the firm's work is pan-European in scope and it emphasises the depth of its practice internationally as a distinguishing feature of the practice. Tax teams from several countries, including the UK, were involved in advising telecommunications company Ciena in its acquisition of Nortel Networks. This involved acquisition of assets in 36 countries across Europe, Asia, the Middle East, Africa and North America. The tax teams assisted Ciena in devising and implementing structure to integrate the assets acquired into its existing business in the most efficient manner, encompassing international tax and cross border structuring considerations. The firm's clients include a number of financial institutions as well as multinational companies acting in both an inbound and outbound capacity.

The firm's UK and Spanish tax departments were also involved in the acquisition of Brazilian mining company Vales' aluminium mining business by aluminium and renewable energy company Norsk Hydro. This was one of the largest M&A deals of 2010 and necessitated implementing a complex structure to accommodate the international elements of the transaction and ensure that the tax matters in each jurisdiction involved were dealt with effectively. The tax department is capable in both standalone tax work and corporate support matters and Sean Finn specialises in international tax and tax controversy matters.

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This year, Simmons & Simmons was recognised as the European Financial Services Tax Team of the Year at the International Tax Review European Awards, reflecting the firm's cross-jurisdictional strength in financial services. In London, Nick Cronkshaw ... [more]

This year, Simmons & Simmons was recognised as the European Financial Services Tax Team of the Year at the International Tax Review European Awards, reflecting the firm's cross-jurisdictional strength in financial services. In London, Nick Cronkshaw leads the corporate tax team which has seen a rise in M&A and real estate tax issues this year as the financial sector continues recovery. Martin Shah coordinated advice given to British Land on tax efficient structuring of their proposed construction of new headquarters for one a Swiss investment bank on Broadgate, a building worth some £600 million. Revisions were necessary to British Land's joint venture agreement with Blackstone, complicating tax matters in an already intricate structure. Simmons & Simmons coordinated the tax elements of corporate restructuring, new debt finance taken by British Land and various real estate issues in a project involving a multitude of advisory teams. The firm capitalised on work done for BlueCrest Capital Management last year as Aron Joy and Candice Nichol supported Shah in the buyout of Man Group's 25.5% stake in the fund by Blue Crest's partners in March 2011. Financial support was provided by way of a senior debt facility arranged by HSBC and RBS and issue of loan notes by Blue Crest. Each of these had to be considered when designing the overall structure to minimise tax liability, especially in light of the potential impact of raising the senior debt facility against the business' cash flow. The firm is highly regarded by both clients and competitors in certain sectors. A partner at one firm said that "Simmons & Simmons is our main competitor in financial services tax advice." [hide]

SJ Berwin's tax department comprises 18 partners and 28 other fee earners under department leader Heather Corben. The firm is distinguished from competitors by the extent of work undertaken in private equity, M&A and real estate funds. The team's expertise ... [more]

SJ Berwin's tax department comprises 18 partners and 28 other fee earners under department leader Heather Corben. The firm is distinguished from competitors by the extent of work undertaken in private equity, M&A and real estate funds. The team's expertise in all three of these areas was important to its work for Pantheon Ventures in the sale of the business to AMG. Pantheon had to be restructured into a limited liability partnership before the sale and the resulting tax issues coordinated across New York, Hong Kong and London. Corben led the team that advised British Land on its joint venture with Oxford Properties, a Canadian pension and investment fund, to begin the $777 million development of its Leadenhall building. Using the right structure for the joint venture was essential to ensure the different characteristics of Oxford Properties and British Land were accommodated. As both debt and equity funding was used to facilitate the joint venture, the particular consequences arising in respect of the real estate investment trust (REIT) rules as well as SDLT and VAT had to be considered. New partner Giles Bavister oversaw Crown Estate's appointment as manager of Norges Bank Investment Management's (NBIM) $725m million 150 year lease of Regent Street. The structure needed to accommodate various commercial objectives of both parties and due to the public profile of Crown Estates had to be capable of withstanding close scrutiny. This involved a number of SPVs being interposed in the chain of ownership and deployment of partnerships within the structure to preserve efficiency and prevent tax leakage. Consultation with HMRC to obtain clearance for the treatment of SDLT in the transaction was also highlighted by Corben as an important feature. The firm notes that while it has seen a rise in instructions over the year, much of the new work relates to cross border restructuring and advisory matters rather than the transactional work which was the former mainstay of the department.

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American law firm Skadden Arps Slate Meagher & Flom has a well established tax practice in London under Tim Sanders, who also heads the European tax practice. The practice now numbers five partners and six other fee earners between its tax and tax controversy ... [more]

American law firm Skadden Arps Slate Meagher & Flom has a well established tax practice in London under Tim Sanders, who also heads the European tax practice. The practice now numbers five partners and six other fee earners between its tax and tax controversy teams. The department's clients include financial sector companies such as Citigroup, commodities company Signet Group and investment funds such as Ziff Brothers Investments and Asset Management Finance Assurances. The firm's reputation in both the UK and the US ensures that it has a steady flow of transatlantic tax matters. A recent example was the sale of Pantheon Funds by Northwestern Mutual Life Assurance on which Sanders coordinated the tax aspects and involved cross-border tax issues.

The tax team also advised an energy company and an investment fund in a joint venture to purchase the majority of the African businesses of a multinational oil company. Skadden's team advised the companies involved on the financing of the purchase including the most favourable structures to deploy to ensure the most favourable tax treatment was obtained. As such transactions suggest, the firm has a very strong M&A practice and much of the tax department work is aligned to M&A projects of its corporate department. However, the firm is also capable in tax controversy. This year, James Anderson has been advising an American financial institution challenged by the US Internal Revenue Service on foreign tax credits the company received in relation to UK taxes paid in 2001 and 2002. Anderson and the lawyers involved are providing assistance to their American litigation colleagues on the technical tax aspects in the UK.

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Sullivan & Cromwell's London tax team is led by Michael McGowan, drawing support from two US qualified partners and three fee earners. With strong links to the firm's American practice, the London arm of Sullivan & Cromwell is well equipped to deal with ... [more]

Sullivan & Cromwell's London tax team is led by Michael McGowan, drawing support from two US qualified partners and three fee earners. With strong links to the firm's American practice, the London arm of Sullivan & Cromwell is well equipped to deal with clients' transatlantic needs. For example, the tax team was involved in the sale of American Life Insurance Company and Delaware American Life Insurance Company to MetLife. The number of international subsidiaries of the sellers placed structuring for tax purposes at the centre of the transaction and was a particular concern of the buyer. The firm was able to reach a position agreeable to both parties as regards the tax treatment though after substantial negotiation. McGowan and Eric Wang both advised on York Capital Management's disposal of their stake in Credit Suisse Asset Management. The transaction was complicated from a tax perspective by the inclusion of an earn-out in the agreement and the need to restructure the York group for tax efficiency during the purchase. The firm counts financial institutions such as Société Générale Corporate and Investment Banking and insurance group AIG Europe amongst its clients. The firm is building a good reputation in the UK and one rival commented that "Sullivan and Cromwell is one of the better tax practices in London among American firms".

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Travers Smith's six partner tax team is led by Kathleen Russ who specialises in private equity transactions, an area where both the firm generally and tax department are particularly strong. Clients of the firm's tax department include Phoenix, Bank ... [more]

Travers Smith's six partner tax team is led by Kathleen Russ who specialises in private equity transactions, an area where both the firm generally and tax department are particularly strong. Clients of the firm's tax department include Phoenix, Bank of Scotland Integrated Finance, 3i, Exponent, and Bridgepoint. Partner Emily Clark specialises in fund formation and in late 2010 coordinated the tax elements of the formation of hedge fund management partnership DG Systematic Trading. The partnership acts as the investment manager of Brevan Howard Systematic Trading Fund. This entailed the establishment of offshore holding vehicles and framework agreements to manage the relationships between the parties involved posing several tax issues that Travers Smith team had to solve in a commercially viable manner. The firm also advised Silverfleet Capital in its acquisition of footwear chain Office. As the transaction was a management buy-out backed by Silverfleet the firm deployed corporate structures in the purchase to streamline the tax treatment of the company in future and ensure that Silverfleet will be able to exit in a tax efficient manner in future.

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Michael L'Estrange heads Watson Farley & Williams' tax practice in London. Their tax work is primarily related to structured finance, corporate support in M&A transactions, capital raising and property transactions as well as general corporate tax advice. ... [more]

Michael L'Estrange heads Watson Farley & Williams' tax practice in London. Their tax work is primarily related to structured finance, corporate support in M&A transactions, capital raising and property transactions as well as general corporate tax advice. The tax department is also capable in tax controversy matters and is presently advising a number of shipping companies challenged by HMRC. The firm generally has a particularly good reputation in both shipping and energy and so it is no surprise that the tax department is well regarded in these sectors. The firm's reputation in these industries is reflected in the clients relying on the team for their tax advice. Shipping companies such as Seaspan and Golar both rely on Watson Farley & Williams for tax matters. In response to client demand, the firm has recently established an Aviation & Aerospace practice which has provided much work for the tax department recently.

L'Estrange and Chris Comyn also suggest one of the department's strengths is in structured finance matters, in particular asset based financing. This means that much of the tax work the firm does is tax driven. While the tax department of the firm is able to provide support on transactional matters, Comyn suggests the real strength of the practice is its ability to conduct complex transactions where favourable tax treatment is the driving purpose of the matter.

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Weil Gotshal & Manges' corporate tax practice, headed by Sarah Priestley, is part of its tax, benefits, and executive compensation group. This endows the department with ability to advise on the tax implications of pensions and employee incentives both ... [more]

Weil Gotshal & Manges' corporate tax practice, headed by Sarah Priestley, is part of its tax, benefits, and executive compensation group. This endows the department with ability to advise on the tax implications of pensions and employee incentives both generally and in transactions, with partner Joanne Etherton specialising in pensions and pension funds. The firm is well represented in the private equity sector and Lion Capital, Summit Partners and HM Capital Partners are among the private equity firms who have relied on Weil's tax department for advice. The tax department is well practiced in advising on M&A and real estate transactions due to the strengths of those departments in London.

Brenda Coleman advised wholesale insurance broker Swett & Crawford on its merger with reinsurance and specialist retail insurance company Cooper Gay. As Swett & Crawford is one of HM Capital's portfolio companies, structuring was a key consideration in the transaction to ensure that HM Capital would still be able to exit without incurring unnecessary tax charges. However, the firm is not limited to transactional matters and is also capable in cross border structuring and restructuring as well as indirect tax.

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Baker Tilly's tax practice has been bolstered this year with the addition of five partners to increase the number of the practice's partners to 54. The firm's clients are mostly small and medium sized business such as London United Busways, Neutrahealth ... [more]

Baker Tilly's tax practice has been bolstered this year with the addition of five partners to increase the number of the practice's partners to 54. The firm's clients are mostly small and medium sized business such as London United Busways, Neutrahealth and Avanta Group. However, the team led by Joe Burnie also has a cross-border capacity by virtue of their membership of the Baker Tilly International network of firms, which is particularly strong across Europe. Notable work for the firm this year included advising the management team of a company who conducted a management buy-out when the company entered administration. This required detailed tax planning since part of the consideration was provided in loan notes. Kevin Phillips and Shaheda Natha coordinated the tax issues in the sale of a business in July 2010. A pre-completion hive down of the business to a new company was undertaken to resolve the tax issues of the company selling the business. The firm's capability in refinancing and restructuring is illustrated in its reorganisation of a group with a Jersey holding company. Due to bonds issued by the group in Canada, the team involved had to consider cross-border issues throughout the restructuring process. [hide]

Cleary Gottlieb Steen & Hamilton's tax practice is said by competitors to have been more visible in the market this year than in previous years. The firm is highly capable and well renowned in M&A matters in particular. This year, it represented fund ... [more]

Cleary Gottlieb Steen & Hamilton's tax practice is said by competitors to have been more visible in the market this year than in previous years. The firm is highly capable and well renowned in M&A matters in particular. This year, it represented fund manager Hellman & Friedman as sellers when fund manager Henderson proposed to buy Gartmore Group. As the bid is to be structured by way of a share-for-share exchange and the target is based in the Cayman Islands, cross border tax issues are an important consideration in the transaction. Department head Richard Sultman specialises in M&A, corporate finance and capital markets matters, reflecting the strengths of the firm generally. Sultman has experience working in New York and so the firm is doubly well equipped to advise on outbound UK investment in the US and inbound US investment.

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Transfer pricing and employee incentives are two areas which the tax department of CMS Cameron McKenna focuses on with distinct teams in its tax department dealing with those issues. Richard Kroker heads the tax team and specialises in real estate tax ... [more]

Transfer pricing and employee incentives are two areas which the tax department of CMS Cameron McKenna focuses on with distinct teams in its tax department dealing with those issues. Richard Kroker heads the tax team and specialises in real estate tax matters, including real estate funds and their formation while consultant Nick Foster-Taylor leads the transfer pricing practice and Nicholas Stretch heads the employee incentives team. The firm's clients are both domestic and multinational companies in a variety of industry sectors, though financial services, textiles, automobile, medical equipment and pharmaceuticals and high technology are industries where the firm is especially well represented. Recent highlights for the department included their role in advising Lyceum Capital and the managers of high street food chain EAT on their buy-out of the company. The firm covered all tax aspects of the transaction, but highlights the involvement of its employee incentives team. Other private equity firms who have sought the firm's tax advice include AAC Capital Partners and it also counts estate agent Savills and National Australia Bank among its clients.

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Dorsey & Whitney's tax practice in London has a good reputation for tax litigation and department head Simon Whitehead is noted in the market for his ability in that area. Both Philippe Freund and Paul Farmer are barristers and sit as part of the tax ... [more]

Dorsey & Whitney's tax practice in London has a good reputation for tax litigation and department head Simon Whitehead is noted in the market for his ability in that area. Both Philippe Freund and Paul Farmer are barristers and sit as part of the tax team at the firm. This ensures that the firm can provide a comprehensive service to clients whose tax controversies go to court. Farmer is head of the EU practice group and is experienced in litigating tax matters before the ECJ. Michael Anderson is also partners in the group with five associates completing the team. The firm also provides transactional tax advice to clients though competitors comment that they are not especially visible in M&A tax matters.

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Accounting firm Grant Thornton has particular ability in transfer pricing compliance and advice, though provides services in corporate tax, indirect tax, cross border structuring and restructuring as well. The firm has been bolstered this year by the ... [more]

Accounting firm Grant Thornton has particular ability in transfer pricing compliance and advice, though provides services in corporate tax, indirect tax, cross border structuring and restructuring as well. The firm has been bolstered this year by the arrival of former Ernst & Young partner Martin Lambert. Standout matters for the firm this year include the redomiciliation of a UK group to Switzerland and the transfer of aspects of its business there. The firm created a Swiss holding company to transfer parts of the business to in order to avoid CFC charges in the UK. Due to the value of the IP transfers involved and the transfer pricing implications, the team from the firm consulted HMRC to obtain clearance for the transaction before completing the matter. The firm also provided an opinion on the tax issues of a multinational operating in the UK involved in a dispute with HMRC over the compatibility of UK branch loss relief rules with European legislation on tax. Though not lead advisers to the client, the issues concerned were highly complex and are pending decision in the ECJ. [hide]

Mayer Brown's tax department has been developing its standalone tax services to compliment its abilities in M&A and capital markets matters. Much of this standalone work involves structuring, which is often international, and the firm is also capable ... [more]

Mayer Brown's tax department has been developing its standalone tax services to compliment its abilities in M&A and capital markets matters. Much of this standalone work involves structuring, which is often international, and the firm is also capable in tax dispute resolution and employee incentives. A recent example was designing a bespoke structure for British Land that enabled the group to change how some of its portfolio properties were held to facilitate external investment and sales in a tax efficient manner via partnership structures. Partner James Hill this year advised on the reverse takeover of the gas transporter and connections company Fulcrum Group from National Grid. Funds for the takeover were raised by a conditional placing with Cenkos Securities adding an additional layer of complexity to a matter where tax structuring was paramount.

Practice leader Peter Steiner specialises in real estate, joint ventures and corporate reorganisations which often have cross border elements. A number of high profile clients such as JP Morgan Chase, Ally Financial and GMAC UK rely on the firm for tax advice. Though the firm has developed its standalone tax practice, it is particularly capable in M&A matters and the tax department is often engaged in matters generated by the corporate department.

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The tax department of McDermott Will & Emery is led by the transfer pricing specialist Peter Nias and comprises four partners, one associate and a recently added a tax director from one of the big four accounting firms. The firm is capable in a range ... [more]

The tax department of McDermott Will & Emery is led by the transfer pricing specialist Peter Nias and comprises four partners, one associate and a recently added a tax director from one of the big four accounting firms. The firm is capable in a range of tax matters including corporate support and M&A work, but focuses on tax planning, structuring and restructuring. Two of the practice's partners focus on various international tax and cross border structuring issues and Nias is chairman of the International Tax Sub-Committee of the Law Society's Tax Law Committee. Recent highlights of the firm's work include the restructuring of a FTSE 100 group's global brand to maintain protection under intellectual property laws and enhance brand value in a tax efficient manner. The team is also capable in personal tax structuring and wealth management for high net worth individuals.

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US law firm Shearman & Sterling's London tax practice is led by Iain Scoon, supported by one counsel and one associate. The team's transatlantic links this year facilitated its advisory role in New England Sports Ventures' (NESV) well-publicised acquisition ... [more]

US law firm Shearman & Sterling's London tax practice is led by Iain Scoon, supported by one counsel and one associate. The team's transatlantic links this year facilitated its advisory role in New England Sports Ventures' (NESV) well-publicised acquisition of Liverpool Football Club. Inventive tax advice was necessary to allow NESV to make the acquisition in a tax efficient manner in both the UK and the US. In the UK, this entailed ensuring that the capitalisation and waiver of some of the Liverpool group's debts was not treated as income for tax purposes. This was just one of many considerations necessary to ensure the deal was structured in manner that would avoid antagonising supporters of the club as well as creating a commercially workable solution for the parties involved. Of counsel Simon Letherman was in charge of the tax driven acquisition of BP's Colombian business by Ecopetrol. Tax was a central issue in the $1.9 billion acquisition as Ecopetrol agreed to buy BP's tax structuring as part of the business. Associate James Leslie and Scoon advised Tata Steel on the disposal of its Teesside Cast Products business. Tax issues in the asset sale were complicated by the age of some of the assets. Assets bought in 1982 had to be re-based for the transaction, creating some unique tax issues around capital receipts and balancing charges and allowances. Transitional service agreements were used to ensure a tax efficient extraction of assets for both seller and buyer. The joint venture entered by the parties to secure joint use of the Teeside site also called the firm's structuring expertise to the fore.

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