Following the UK's vote to leave the EU on June 23 2016, advisers have been busy talking taxpayers through the potential implications and changes to the tax market. It was reported that companies were more cautious before the vote, with various Brexit clauses included in contracts. The transaction market, in particular, slowed down as a result of the uncertainty.
Whether the UK tax market will benefit from the British exit ('Brexit') from the EU, and what changes will be made to the tax legislation remains unclear, but advisers agreed that the UK may become more attractive as it will be able to compete with other European countries. "A lot of our corporation tax rules are designed with the EU in mind. Until we know what the EU-UK relationship is going to look like, it is difficult to predict what the tax consequences will be," said Tom Jarvis, partner at Watson Farley & Williams.
"I think [Brexit] will be a huge topic in every area of everything that we do for a long time," said Richard Stephen, who is a partner at Watson Farley & Williams. "It will dominate tax conversation just as much as it dominates anything else."
Advisers agree that Brexit will remain a huge topic in tax, as well as most other areas of business, and will create a lot of work for professionals. "The political situation needs to stabilise. I think there will continue to be the need for advisory services from tax firms but I think that the nature of the advice will be dictated by the direction that the negotiations take or indeed whether or not a situation arises where we try to walk back from Brexit," said Sandy Bhogal, head of Mayer Brown's tax group.
Even before the vote to leave the EU, the UK had experienced a lot of turbulence in its tax climate. From April 6 2016, the notional 10% tax credit on dividends was abolished and a new £5,000 tax free dividend allowance was introduced. The capital gains tax (CGT) rate was also cut in the 2016 Budget and those paying basic-rate income tax will pay CGT at 10%, down from 18%, and higher-rate taxpayers will be charged at 20%, down from 28%.
The focus on anti-tax avoidance has continued to be high on the agenda as the OECD's BEPS Project and the EU's Anti-Tax Avoidance Directive have become a key topic. "Base erosion and profit shifting, I'm afraid, is where it is at – particularly Action 4 on interest deductibility on the non-contentious side," said Eloise Walker, partner at Pinsent Masons.
Following the BEPS recommendations, new rules were introduced to limit corporate tax deductibility of interest expenditure. Advisers said the rules come as the UK is keen to take a leading role in the implementation of international avoidance measures, but agree that it is causing a lot of uncertainty.
The UK has taken a number of steps to align its tax system with the OECD's recommendations to combat tax avoidance and increase transparency. "We are now seeing individual jurisdictions proposing legislation to implement the BEPS proposals and certainly in the UK, the BEPS-inspired changes are going to keep us very busy," said Sara Luder, head of tax at Slaughter and May.
On March 16 2016, HM Treasury announced new measures relating to hybrid mismatches, interest deductibility, royal withholding tax and transfer pricing. The UK has already committed to introducing the OECD's recommendations from 2017 with draft legislation published in December 2015. The 2016 Budget announced a new anti-avoidance provision to counteract arrangements when the main purpose of the arrangement is to obtain a relevant tax advantage by avoiding the new anti-hybrid rules. Three changes to the withholding tax rules for royalty payments were also announced: the categories of royalties to withholding tax is to be expanded to include royalties paid in respect of all intellectual property, which for the first time would include payments made in respect of trademarks and brand names; the definition of UK source would be amended and withholding would apply where the payments are connected with a UK permanent establishment of a foreign company; and new anti-avoidance measures will be introduced to deny access to the UK's tax treaties where the payment is made by a UK person to a connected party under an arrangement.
"Even though we've got anti-avoidance coming out of our ears, and even though we don't actually need to do anything to tackle the problem, we've got a new set of rules coming in on around the interest cap at 30% of earnings before interest, taxes, depreciation and amortisation (EBITDA)," said Walker.
The new rules for interest deductibility, effective from April 1 2017, include a fixed ratio rule (with a 30% interest cap); a group ratio rule, based on the external net interest to EBITDA ratio for the worldwide group; a group threshold of £2 million ($2.6 million) net UK interest expense; rules to ensure that the restriction does not impede the provision of private finance and, finally, rules addressing volatility in earnings and interest in the rules.
"There will be lots of disputes because businesses won't always know where they stand under the new rules," said Jason Collins, head of tax at Pinsent Masons. "With new areas of dispute, and the need for tax authorities to increase their yield, tax compliance has become much more contentious, so tax directors need to be much more aware of the risk of dispute and what they need to do to prepare."
The new rules and legislation, as well as the international trend of increasingly aggressive tax authorities, have resulted in HMRC adapting a more comprehensive approach and trying to stay on top of the changing tax climate. Advisers reported that HMRC is not aggressive, although it is evident that they are under pressure to appear so. "There is clearly a huge amount of political pressure on HMRC to be seen to be tough and to be seen to maximise tax revenues, but Government policy is still to have a competitive corporate tax regime," said Luder.
As the process of leaving the EU will be lengthy, advisers said they expect many legislative changes to take place beforehand. "The likelihood is that the BEPS agenda will be implemented before Brexit, so the work that tax advisers are doing will still continue because BEPS remains a live issue," said Bhogal. "There has been no suggestion as yet that the UK will put the brakes on BEPS implementation because of Brexit, even though that may be sensible in certain circumstances."
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|Corporate Income Tax||20%||A B C|
|Capital Gains Tax||20%||D|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||20%||E|
|Branch Remittance Tax||0%|
Allen & Overy's tax department is co-headed by Christopher Harrison and Viman Tilakapala. The team is highly respected among its peers and is particularly strong in finance-related tax matters. It has a comprehensive understanding of international taxation in business terms.
The team supports clients from a range of industries on various tax matters including restructuring, tax audits and investigations, litigation, corporate tax, indirect tax, investment fund management and cross-border transactions.
David Pert leads the tax practice at Alvarez & Marsal, Taxand UK, and is supported by a team of tax and legal professionals with broad expertise and experience. As part of the global Taxand network, the firm is able to help mitigate risk and manage tax burden while providing multi-jurisdictional tax support to clients with the aid of professionals throughout the network.
The team assists clients in designing and implementing solutions across a range of areas including transfer pricing, international tax, corporate tax, indirect tax, M&A, real estate tax and business restructuring. It is highly experienced in the field of corporate tax as well as assisting high net-worth individuals.
Over the past year, the team conducted various client workshops on topical tax issues. In one deal, the team advised an equity investment and asset management group on the acquisition of a business operating US medical care centres. The team was also commissioned by the regulator of the UK water and waste management industry, Ofwat, to carry out an independent review of the tax affairs of the 18 companies operating regional monopolies following criticism from the Public Accounts Committee.
The firm's clientele ranges across a broad spectrum of industries including real estate, retail and consumer goods, pharmaceuticals, media and technology and includes a number of FTSE100 companies, overseas headquartered multinationals and permanent establishment houses. Clients praise the firm as excellent and it comes highly recommended. One client described the staff as "very pro-active and quick to respond to queries".
The tax practice at Ashurst in London is overseen by Richard Palmer, who specialises in UK and international tax planning and focuses on the tax aspects of corporate disposals and reconstructions. The tax team offers practical and strategic advice on a wide range of matters including cross-border transactions, fund structuring, tax structuring, VAT litigation and tax disputes in the UK tax tribunals and the European Courts of Justice.
Baker & McKenzie's tax department is made up of 53 professionals, including 14 partners, who have multidisciplinary backgrounds in tax advisory. The full-service firm has particular strengths in international tax planning, complex transactional tax and tax controversy.
The firm comes highly recommended by clients. One said: "I find them to be technically sound, creative, responsive and flexible in how they work with us. They take the trouble to understand what it is we are trying to achieve in a broader sense rather than simply focussing on a tax technical angle, which ensures that whatever is recommended is ultimately meeting business objectives and can be implemented effectively."
Alex Chadwick is the managing partner of the firm and oversees all tax activities. He specialises in advising on the tax aspects of corporate finance, M&A, joint ventures and corporate restructurings. He works closely with Mark Delaney who is the head of VAT and indirect tax and advises on a broad range of VAT-related matters. He has extensive experience assisting in the planning of financing arrangements, providing VAT litigation and dispute support and compiling multijurisdictional VAT assurance reviews. Richard Fletcher, head of transfer pricing, has more than 30 years' experience as an international tax adviser and has extensive expertise in transfer pricing and related tax matters.
The team worked as a special tax counsel on an $18 billion merger between insurance brokerage Willis Group Holdings and professionals services firm Towers Watson & co which was completed on January 5 2016.
Baker & McKenzie supports clients from all industry backgrounds, and is particularly strong in technology, financial services, private equity, energy and natural resources and retail and consumer products.
Jim Meakin is the national head of tax at Baker Tilly. The team of professionals offers a full suite of tax services to UK clients with particular strength in financial and business support. It offers support in corporate tax, tax risk assessment and global management and runs a private client service line, which is led by Gary Haynes.
Meakin has more than 20 years of experience in tax and specialises in corporate and transactional tax, as well as professional partnerships.
Michael Wistow is the head of Berwin Leighton Paisner's tax department and specialises in corporate, finance and real estate industry based transactions and clients. The international law firm offers tax services across an array of industries with focus in real estate, private equity, funds and investment structures.
The team of tax professionals has a wealth of expertise and knowledge of the global and domestic tax environments and supports clients in both contentious and non-contentious tax matters.
The UK tax practice at Cleary Gottlieb Steen & Hamilton benefits from a global network with tax teams in the Americas, Europe, Middle East and Asia. The firm has a wealth of experience advising international clients on a range of tax matters, particularly those related to M&A, strategic international tax planning, corporate transactions and structuring.
Chris Davies is the global head of Clifford Chance's tax, pensions and employment practice, leading a large team with years of experience in corporate tax, finance and complex cross-border transactions. The large team advises on a range of tax matters including M&A, real estate, finance, capital markets, funds and investments, employee incentives, VAT and indirect tax.
The team is able to assist clients from all industries and of all sizes and has particular experience working within the fields of banking, financial services, funds and investment management, insurance and real estate.
This year, the team advised National Australia Bank (NAB) on the demerger and IPO of Clydesdale Bank, valuing Clydesdale at £1.6 billion ($2.1 billion). The advice involved a complex and innovative structure as to meet tax and regulatory requirements in various jurisdictions.
Clifford Chance has expertise in supranational taxation which, following the international changes in the tax market, has seen increased demand. Dan Neidle is particularly strong in this area and the team is able to assist with, ongoing compliance and for legal documentation and structures.
CMS Cameron McKenna houses a full-service tax team that deals with day-to-day tax advice as well as complex tax matters such as corporate and M&A, fund management, VAT and tax litigation. Richard Croker leads the corporate tax practice and has been a partner at the firm since 1997. His practice areas include tax planning for real estate transactions, fund structuring, joint ventures, private finance and projects transactions, as well as M&A across a number of sectors.
Matt Ellis is the newly-appointed managing leader Deloitte's tax practice in the UK. He has more than 30 years of experience and has advised many large companies. The accounting firm offers a range of tax services ranging across various industries. Andy Wilde is an international tax partner and leads the northern tax practice in the UK and Deloitte's international tax practice in the Europe, Middle East and Africa (EMEA) region. He has more than 27 years of experience in international tax and has assisted many UK and US-based multinationals.
DLA Piper's tax practice in the UK is headed by Richard Woolich. The deparment is able to assist clients in domestic, European and international tax matters including indirect and direct tax, transfer pricing and tax disputes.
The team of six partners and 15 professionals supports clients across all industries with strong expertise in banking and financial services, technology and telecommunications, real estate, hospitality and leisure, sports, media and entertainment and professional and business services.
One client said: "We have a wonderful relationship with Richard [Woolich]. He is always ready and available to help and is extremely knowledgeable in his field of law. Nothing is too big or small for Richard. He understands the needs of his clients and always seems willing to go the extra mile to assist. I would definitely recommend DLA Piper."
The UK team is fully integrated in the DLA Piper network, which has more than 300 tax professionals in offices throughout the UK, Europe, Asia-Pacific and the Americas. The team expanded its tax offering by recruiting three strong transfer pricing professionals to assist on APAs, supply chain planning, tax impact modelling and valuations.
The tax practice at Eversheds assists corporate and private clients in a range of industries under the leadership of David Jervis. It specialises in tax litigation, corporate tax, employee share schemes, VAT and indirect tax and has particular emphasis in consumer services, energy and natural resources, financial institutions and the public sector.
EY's managing partner Jason Lester oversees the firm's tax operations in the UK and Ireland. He has more than 20 years experience in international and corporate tax with extensive expertise of the UK tax system.
The team of tax and legal professionals has a wealth of experience and competencies in the international business landscape.
David Haworth is the head of Freshfields Bruckhaus Deringer's tax practice, which comprises 10 tax partners and 27 other professionals in the London office. The professionals have vast experience supporting clients from a variety of sectors such as finance, energy and natural resources, real estate and technology, media and telecommunications (TMT).
The firm also provides solutions in transactional work, tax investigations and disputes, tax planning and policy matters with respect to multi-jurisdictional regulations. It focuses on global tax compliance, offering consultations and tax optimisation advice for multinational corporate and private clients.
In one deal, Murray Clayson, Sarah Falk, Faye Coates and Emily Szasz advised Anheuser-Busch InBev in its takeover of SAB Miller valued at £71 billion ($93 billion).
The client of another firm said: "In the UK we use Freshfields. Helen Lethaby is fantastic lawyer. Really impressed with the service. Knows her stuff, lot of trust, really smart. Really responsive."
The firm's international tax practice consists of more than 30 partners and 90 associates in Austria, Belgium, France, Italy, Germany, the Netherlands, Spain, UK and US. The London office houses significant international experience and specialises in cross-border tax.
FTI Consulting's tax department is headed by Marvin Rust. The practice has grown significantly over the past 18 months, building on its expertise in tax depreciation, stamp taxes and debt restructurings by adding senior experience in VAT, transfer pricing, real estate, hotels and hospitality, financial services and private equity and M&A.
One client said: "We would certainly recommend them – they are a great alternative to the Big 4 with more flexibility in several areas."
In one deal, the team advised Travelodge on the structuring of the insurance of its inaugural £390 million ($514 million) yield bond offering. The work included briefing potential investors on the relevant tax history of the group, forecasting under a number of scenarios and guiding on the steps needed to implement refinancing.
FTI Consulting is the UK member of the global WTS network. It works closely with other WTS network members as well as FTI's transaction advisory services, restructuring and insolvency, economic consulting, corporate finance and strategic communications practices.
The firm has recently appointed three new partners from KPMG to its tax practice. Sarah Lane has 20 years of experience in banking, international tax and advising on the interaction between tax and regulation. She also has considerable M&A experience. Peter Scholes is the former head of financing and treasury tax at KPMG and has extensive knowledge in international tax with more than 25 years' experience. Ben Tausig has 10 years of experience advising multinational insurance groups on tax and capital efficient group structures, UK and US controlled foreign company rules and overall tax strategy.
Grant Thornton is an international assurance, tax and advisory firm with more than 42,000 professionals across 130 countries. The UK tax department comprises 967 professionals and is headed by Jonathan Riley. It advises more than 40,000 organisations across the public and private sectors to ensure they are tax compliant.
The full-service team assists clients from all industries in a range of tax services including corporate tax, transfer pricing, business restructuring, tax disputes and litigation. It works closely with other Grant Thornton member firms to deliver international tax solutions and frequently work with authorities such as the OECD, HM Treasury and HMRC.
One client said: "Grant Thornton conducted themselves with the highest degree of professionalism, were extremely communicative and very pleasant to deal with. It has been a pleasure working with the team particularly as mainly UK based."
Under the supervision of Isaac Zailer, Herbert Smith Freehills' tax department assists clients in a range of tax matters including international tax planning, corporate tax, dispute resolution, IP management and tax compliance. The team is specialised in capital markets, finance, real estate and the tax-related aspects of employment.
Zailer's focus is in the transport and infrastructure sectors. He also has general expertise in finance and structured finance, corporate M&A, asset management, equity and debt capital markets, company reorganisations and UK property taxation.
Karen Hughes is one of the two global co-heads at Hogan Lovells' tax practice. Her London team offers comprehensive support on a range of UK and international taxation matters with particular strengths in advising on transfer pricing, complex cross-border transactions, M&A, tax audits and disputes. The firm provides assistance to clients from a wide number of industries such as real estate, financial services, insurance and pharmaceuticals.
Innovate Tax is a boutique consultancy firm that differs from other practices as it specialises in the Oracle R12 eBTax module and Oracle Fusion Tax. The team of nine professionals provides a complete end-to-end process for indirect tax clients using Oracle Financials. It provides a superior and cost efficient service to clients worldwide and across all industries.
Andrew Bohnet is the managing director and oversees the practice, which offers advisory services, integrated tax solutions and support and specialises exclusively in Oracle eBusiness tax, design, and analysis, implementation and support services.
One client said: "We chose them over other bigger and more established firms because they not only provided the most cost-effective solution but also the most comprehensive one too with an expertise in implementing indirect tax in Oracle that we felt was amongst the best in the market."
Kaye Scholer's UK tax practice integrates its activities with other tax professionals throughout the firm's global network to provide high-quality assistance to its clients. The firm has expertise in private equity, investment and divestment projects, M&A and international structuring.
Daniel Lewin is a key tax partner and has a wealth of experience advising clients on tax matters including corporate tax, private clients and high net-worth individuals, international tax planning, cross-border tax and compliance with UK and international financial services regulations.
Heather Corben leads the London tax team at King & Wood Mallesons. The team of tax professionals has a wide range of expertise and is focused on advising corporate clients on UK and international tax matters. Corben has been with the firm for 20 years and has experience advising European, Asian and US clients on corporate real estate deals including acquisition, developments, joint ventures and disposals.
KPMG's tax department assists clients all over the world through a full range of services including tax management consulting, value-chain optimisation and analysis, corporate tax and indirect tax, and also assists private public clients.
Michelle Quest was appointed UK head of tax, pensions and legal services in February and has been working as a tax partner for 12 years. She works closely with Jane McCormick who is KPMG's global head of tax. The former head of tax Karen Briggs was appointed as KPMG's 'head of Brexit' this year to supplement the firm's executive leadership team.
The tax team at Latham & Watkins supports clients with queries relating to transactional tax, UK and international tax, compliance, tax controversy and tax structuring for benefit, compensation and employment schemes.
The UK department works closely with more than 100 tax professionals throughout Latham & Watkins' global network, enabling the ability to supervise clients in complex M&A and cross-border transactions.
Linklaters handles day-to-day tax activities as well as complicated tax matters related to M&A, corporate transactions, indirect tax, tax litigation and dispute resolutions. The team is overseen by Yash Rupal and offers a broad scope of tax services covering corporate tax, indirect tax and tax controversy.
Rupal assists a wide range of clients on transactions (including M&A), corporate reorganisations, capital markets transactions and tax planning. He specialises in cross-border and has particular interest in finance transactions and the development of new financial products and structures.
Damien Crossley is the head of the tax group at Macfarlanes. He has advisory experience in investment funds and financial structuring and advises on a broad range of tax and structuring issues. The tax team comprises tax lawyers with multi-disciplinary experience and assists clients on several tax matters such as those related to hedge funds, private equity, corporate tax, M&A, tax litigation and transfer pricing.
Mayer Brown's team of tax professionals is headed by Sandy Bhogal and offers a full range of services covering corporate and commercial issues of direct and indirect taxes. The team also provides transaction support, especially in relation to M&A, reorganisations, buy-outs, joint ventures, capital markets, leveraged and structured finance and real estate.
It also provides specific project advice, planning and structure advice and offers a full service on employee incentives and the tax aspects of employment-related securities, tax dispute resolution and transfer pricing services.
In one deal, the team advised global asset manager Brookfield Asset Management, and affiliated entities, on a high-profile acquisition by one of its global real estate opportunity funds of Center Parcs from Blackstone.
Bhogal has a wealth of knowledge and experience ranging from general corporate tax advice to transactional advice on matters involving corporate finance, banking, capital markets, asset finance and property. He also has significant expertise with corporate tax planning and the development of domestic and cross-border tax-efficient structures.
Mayer Brown's transactional and consulting tax practices include partners in four US offices, the UK, Germany, France, Belgium and Singapore covering a range of tax services.
McDermott Will & Emery's global practice employs more than 200 tax professionals. Tom Scott leads the team in London working closely with James Ross and Matthew Herrington.
The firm advised Olam International, a Singapore-based global agribusiness company operating in 65 countries on the tax aspects of its $1.3 billion acquisition of Archer Daniels Midland Company's global cocoa business.
Scott focuses on international and domestic corporate and commercial tax issues, including M&A, cross-border restructuring and tax dispute resolution. Ross is an experienced tax lawyer with particular experience advising US groups in the structuring of UK and European inbound investments and providing advice on technical issues in context of revenue investigations and statutory audits. Herrington has experience negotiating settlements with the UK tax authorities and practices in a range of domestic and international tax matters.
Norton Rose Fulbright provides a full range of tax services to domestic and foreign clients under the leadership of Dominic Stuttaford, who is an experienced corporate tax, finance, M&A, and international tax planning adviser, as well as being the head of tax for Europe, Middle East, Asia and Brazil.
The team's practice areas include asset finance, capital markets and financial instruments, corporate finance, insurance, investment funds, Islamic finance, real estate, energy taxation and tax dispute resolution.
The tax team at Olswang assists clients on a range of domestic and cross-border transactions, direct and indirect taxes, global transactions, M&A, joint ventures, corporate restructuring and private equity. The firm covers a range of industries, with expertise in handling tax matters relating to the real estate, finance, media, and technology, IP and employment sectors.
Arun Birla and Jiten Tank are key members of Paul Hastings' tax department, working closely with four other professionals. The team has extensive experience in domestic and cross-border corporate and financial transactions and provides innovative, practical and efficient tax advice on the structuring of corporate M&A, IP planning, real estate, structured products, investment funds, restructurings, securitisations, joint ventures, and special investment vehicles. Paul Hastings also supports both local and international enterprises in fund formation and private equity.
Jason Collins leads the tax group at Pinsent Masons which comprises lawyers, accountants, senior ex-HMRC staff and former in-house personnel, enabling the firm to provide commercial advice and deal with both the tax and legal issues at hand.
The practice provides the full suite of tax services and provides innovative solutions to manage clients' risks and has strong expertise in the financial services, technology and infrastructure sectors.
The team is particularly strong in cross-border transactional advice, including M&A, private equity tax and finance tax. It also specialises in contentious tax work ranging from disputes to criminal investigations, and frequently represents clients before the courts.
Three professionals joined the team this year: Andrew Scott, former director for business tax at HMRC's solicitor's office, Matthew Taylor from EY and Valerie Wu from Rothschild.
"I would recommend this firm to others for litigation matters because I've been pleased with the attorneys' level of expertise on the matters I have worked with them on," said one client. "In addition, the attorneys show good solid judgement in matters seeking advice from Queen's Counsel when a broader view is needed. The attorney's act with a sense of urgency while still focusing on every detail as is necessary from a litigation perspective."
Eloise Walker heads the corporate tax practice, working closely with the head of the tax disputes and investigations team, Stuart Walsh.
PwC's UK tax team offers all relevant tax services with emphasis on corporate compliance. The professionals have significant expertise in UK and international taxation and assist domestic clients and foreign enterprises with issues such as compliance, corporate tax and indirect tax. Kevin Nicholson leads the team and has worked for PwC since 1991, with experience working in the North East of England, New York and Hong Kong. Annie Devoy is a key member of the team and oversees transfer pricing operations.
PwC Legal offers a full scope of tax services and has a broad understanding of UK and international taxation. As part of the global network, the tax team is able to advise on a wide range of complex tax matters related to corporate tax structuring, tax litigation and dispute resolution, transfer pricing and global compliance services.
Boutique law firm Rosetta Tax provides efficient and specialised support to corporate and individual clients through its broad advisory offerings and experience. The tax services include cross-border transactions, disputes, M&A, outsourcing and employee share schemes.
The professionals at the firm are experienced in domestic and international tax from law firms and Big 4 accountancy practices. The team comprises a mixture of barristers and solicitors.
Shearman & Sterling advises clients in a range of industries including energy, infrastructure, finance, healthcare, metals and mining and TMT. The team is led by Sarah Priestley, who is a corporate tax specialist. She has expertise in complex UK, multi-jurisdictional and pan-European M&A and private equity transactions. She also advises on the UK corporation tax, VAT and stamp duty aspects of a wide range of commercial transactions.
The firm assists clients in a range of tax services including M&A, spin-offs, restructuring and reorganisations, hedge fund and private equity transactions and tax controversy and litigation.
Under the leadership of Nick Cronkshaw, the tax department at Simmons & Simmons offers a full range tax services including indirect tax, corporate tax, tax controversy, M&A tax planning, international group structuring, capital markets, banking taxes, civil and criminal tax disputes and other contentious issues.
The firm assists clients across a wide range of industries, including asset management, investment funds, financial institutions, energy and infrastructure, TMT and life sciences.
The team acted for the British Land Company and Broadgate REIT Limited on the structuring, establishment and launch of Broadgate REIT, which has £4.5 billion ($5.9 billion) of real estate at the Broadgate Estate, London. Simmons & Simmons assisted on tax and structuring issues and on related amendments to the securitisation of part of the estate.
In another deal, concerning a separate client, Simmons & Simmons acted in a dispute concerning attempts by the Indian income tax commissioners to access foreign investing in Indian securities to Indian minimum alternative taxation (MAT).
One client praised the firm, describing them as commercially and technically excellent.
James Anderson leads the tax practice at Skadden, Arps, Slate, Meagher & Flom. He is a private capital specialist focused on funds, family offices, investment companies and high net-worth individuals. The team has extensive expertise in cross-border matters, particularly related to US/UK deals and private capital. It consists of two partners, three associates and a trainee who are specialists in corporate and financial transactions, derivatives, structured finance, funds and private capital.
The firm assists clients in situations involving high levels of technical, commercial or political risk and excels in areas such as investment management. In one deal, the team assisted the Coca-Cola Company on tax aspects of the merger of Coca-Cola Erfrischungsgetränke AG, Coca-Cola Enterprises, Inc. and Coca-Cola Iberian Partners SA. The deal is a tri-partite joint venture combined with an inversion, which will form a UK PLC listed in New York, Amsterdam and Madrid.
Alex Jupp is the M&A tax leader and is experienced across a range of tax matters, specialising in multi-jurisdictional M&A.
Sara Luder leads the tax practice at Slaughter and May which comprises eight partners and 21 professionals. The team's expertise and experience ranges across all aspects of tax with particular focus on structuring complex M&A and financing transactions.
This year, the firm has been involved in a number of high-profile deals including assisting Royal Dutch Shell on its recommended cash and share offer for BG Group. In a separate deal, it advised Coca-Cola Enterprises on its agreement to combine with Coca-Cola Iberian Partners and CCAEAG to create Coca-Cola European Partners.
The firm comes highly recommended by its clients. One said: "They are technically excellent and bring commerciality and pragmatism."
The UK tax team at Sullivan & Cromwell comprises two partners and three professionals and is led by Ronald Creamer. It offers business-oriented UK and US tax advice on complex cross-border transactions, and delivers practical and tax-efficient solutions to complex domestic and international transactional issues.
The London team has expertise in corporate finance and M&A transactions as well as employee benefits, tax-based structured finance and funds structure and investments. The team also has a wealth of knowledge advising on tax controversies.
The team advised Fiat Chrysler Automobiles and Ferrari on the UK tax aspects of the initial public offering of 10% of the outstanding shares of Ferrari. Before the launch of IPO, the Ferrari group went through a corporate reorganisation that resulted in the establishment of a new Dutch parent company for the Ferrari business and the incurrence, by Ferrari, of debt in order to optimise the capital structure of Ferrari as a public company.
Peter Jackson leads the tax team at Taylor Wessing which employs a total of 10 professionals and is supported by the international network of tax advisers around the globe. The team assists both high-profile and high-value clients across the real estate, finance and corporate sectors as well as advising start-ups and overseas SMEs seeking UK funding or establishing in the UK.
The firm is particularly strong in the real estate sector and represents many blue chip international clients on market transactions and investments and works alongside the firm's residential property practice structuring a wide range of residential investments and developments.
The tax specialists have a wealth of experience and knowledge supporting clients with tax requirements relating to tax compliance, IP enforcements, restructuring, tax disputes, litigation and tax management for private clients.
Harriet Revington has recently joined the team as an associate from Squire Patton Boggs along with Will Egan as a newly qualified solicitor from Simmons & Simmons.
The tax department at Travers Smith supports financial institutions, corporate clients and individuals across the world on the full range of tax matters including private equity, tax investigations, litigation, fund management, corporate taxation and property transactions. Kathleen Russ leads the team, which is highly experienced across an array of sectors ranging from financial services to healthcare, media and technology.
Russ specialises in private equity transactions and assists both institutional investors and management teams in the area. She is a member of the BVCA Tax Committee and is regularly involved in discussions with HMRC.
The team comprises nine partners and has grown significantly over the past five years to meet the demand and diversity of clients.
Richard Stephens leads the tax operations at Watson Farley & Williams and has years of experience advising UK and multinational companies on all aspects of corporate taxation. His team's specific practice areas include maritime, energy and infrastructure, M&A, tonnage tax, leasing and finance. The team also assists high net-worth individuals and family offices, and has distinct corporate and real estate departments.
Tom Jarvis joined the firm from Deloitte in 2015, bringing with him years of corporate tax expertise to the team. He regularly advises multinationals, domestic corporates, financial institutions, inbound investors and private equity houses on a range of deals as well as on tax consultancy matters and disputes.
One client said: "I am happy to recommend Watson Farley & Williams's tax team – especially Tom Jarvis is strong and provide clear and understandable tax advice."
In one deal, the team assisted PNE WIND, an international wind farm developer, on the £100 million ($132 million) sale of its entire UK wind farm project pipeline to Canada-based asset manager Brookfield. The firm's clientele also includes RBS, DONG Energy and BNP Paribas.
Weil, Gotshal & Manges's team of 11 professionals offers a range of services under the leadership of David Irvine and Oliver Walker. It assists with a range of tax matters such as corporate restructuring, tax litigation, employee share schemes and M&A and has a wealth of knowledge of UK and international tax.
The team has multi-disciplinary expertise and specialism in consulting clients from the private equity, financial services, private funds, telecommunications, consumer goods and retail industries.
In one deal, the firm advised Worldpay owners Advent International and Bain Capital in a dual-track process leading to the IPO and listing on the main market of the London Stock Exchange of the company.
One client said: "I would recommend this firm to others because of the expertise they have demonstrated in the long-running litigation we have been involved in with HMRC. They have shouldered the burden of extremely difficult tax litigation and worked seamlessly with the QC and junior tax counsel."
|Tier 1- United Kingdom|
|Baker & McKenzie|
|Freshfields Bruckhaus Deringer|
|Slaughter and May|
|Tier 2- United Kingdom|
|Allen & Overy|
|Alvarez & Marsal, Taxand UK|
|Berwin Leighton Paisner|
|Herbert Smith Freehills|
|Latham & Watkins|
|Norton Rose Fulbright|
|Simmons & Simmons|
|Skadden, Arps, Slate, Meagher & Flom|
|Sullivan & Cromwell|
|Tier 3- United Kingdom|
|King & Wood Mallesons|
|McDermott Will & Emery|
|Shearman & Sterling|
|Weil, Gotshal & Manges|
|Tier 4- United Kingdom|
|Cleary Gottlieb Steen & Hamilton|
|CMS Cameron McKenna|
|Watson Farley & Williams|
|Firms to watch- United Kingdom|