UK Tax

In the increasingly complex area of tax legislation and practice, the depth and breadth of our practice ensures that we are able successfully to support our clients' business needs, whether they are financial institutions, corporates or funds (see also the Employment and Benefits page for tax in that area).

Tax is, to a greater or lesser extent, relevant to most business transactions and, accordingly, our tax practice extends across the entire scope of the firm's work. This means that we work closely with our colleagues in other specialistic areas, enabling us to offer expertise in capital markets, general and specialist banking, corporate and M&A, funds and real estate. In addition, we provide general tax advice to a number of clients (in situations where other legal advice may not be needed) and advise a wide range of clients on the resolution of tax disputes.

Our experience in all aspects of corporate, commercial and finance taxation enables us to provide high quality, innovative tax solutions. We are frequently involved in the first transaction of its kind to be undertaken. We have 40 UK qualified specialists dedicated to tax, including nine partners who are consistently recommended in the major legal directories.

A large proportion of the transactions in which we become involved are cross-border in nature and we will typically be working with our tax colleagues in other jurisdictions, and with local tax advisers in jurisdictions where Allen & Overy does not itself offer tax expertise. We are frequently instructed to provide a "one stop shop" international tax service, coordinating advice in a number of jurisdictions, where there may be either no UK tax element or any UK tax element is minimal. Where US tax is concerned, we also have the benefit of two US tax partners and their five associates in London, in addition to our US tax capability in New York.

"In difficult working environments, good relationships are key to a successful business and the attention to client service at Allen & Overy is outstanding."

Chambers UK 2010, UK Tax

Insight

After an extensive softening up exercise, the emergency budget did not contain any dramatic surprises. Corporates will welcome the reduction in the rate of corporation tax by 1% in each of the next four years, but some will be disappointed with the reduction in the rate of capital allowances and that 2011 will bring only an interim reform of the controlled foreign companies rules, full reform being postponed until 2012.
Tax charges on banks remain on the agenda with a commitment to work towards an internationally coordinated systemic risk tax covering all financial institutions that might contribute significantly to systemic tax risk.

deals & cases

Allen & Overy LLP said today that the GBP1.4 billion residential mortgage-backed securitisation (RMBS) issued by Santander represents a further positive step for the European RMBS market.
Allen & Overy LLP has advised Cable & Wireless Communications on its USD500 million Rule 144A/Reg S bond offering, which closed today. This bond offering forms the final part of the financing structure for the demerger of the Cable & Wireless Worldwide business from the Cable & Wireless Communications business and is listed on the London stock exchange.
contacts

Partner
Mark Brailsford is a partner in the tax department in Allen & Overy's London office. He advises on all taxation aspects of financial transactions, including banking and capital market transactions, securitisations, structured finance, derivatives and other financial products.

Partner
Lydia Challen is a partner in the corporate tax department. Her experience includes in particular advising on restructurings, mergers and acquisitions transactions, private equity and tax structured financing.

Partner
Stephen Fiamma is a partner in the US Tax practice based in London and a member of the US Law Group. He has been a member of the Bars of the State of New York and the United States Tax Court since 1979. Stephen specializes in the taxation of cross-border financings and corporate transactions.


Search