Tax

Allen & Overy is the trusted partner of leading banks, financial institutions and private funding providers across the world.  We have the experience and skills to deliver successful outcomes for the most challenging and novel deals for our banking and finance clients around the world, whether you are raising funds, providing finance or making investments. Our Tax group has unrivalled knowledge of how to structure and optimise domestic and cross-border financial products.

Corporate tax is a complex and dynamic area that affects every aspect of your business throughout its lifecycle. Whether you are raising or investing capital, deciding where to locate your operations, participating in M&A, or returning value to shareholders, tax will have an impact on your decisions.  You need to have the right policies and management structures in place to comply with the ever-changing tax regulations in the jurisdictions where you operate.  You need to manage tax risks from your operations, and allocate risks appropriately when negotiating your transactions.  Working with clients from a wide range of industries and sectors, we have deep expertise in all these areas, which we can tailor to your specific needs and circumstances.

Allen & Overy is a global leader in debt capital markets, with a wealth of experience and expertise across all types of transactions and markets. Our DCM practice works closely with our international Tax team, which provides crucial advice on the tax implications and opportunities of each deal. We help our clients navigate the tax aspects of bond issuances, regulatory capital, corporate hybrids, re-packagings, CLOs, securitisations, Islamic finance and more.

Whether you are launching a new fund, investing in an existing one, or managing a portfolio of assets, we provide practical solutions to the tax challenges you face. We advise fund managers on the optimal tax structure for the fund, ongoing tax issues relating to the fund, and the structure and terms of the deployment of the fund’s capital in making investments. We help institutional investors to structure and negotiate the terms of their investment into funds and other investment structures, from “managed accounts” to minority investments.  Our cross-border expertise extends to real estate, infrastructure, regulated and hedge funds.

Our Indirect tax team help businesses and individuals comply with the complex and evolving rules and regulations around indirect tax regimes, with a special focus on VAT. We advise clients in many sectors and industries on how to optimise their tax position and minimise risks. We provide practical indirect tax advice and legal services that suit your business needs and objectives.

Our Private Equity tax team works closely with our PE practice to provide tailored, pragmatic solutions to the complex issues that arise in PE transactions, including acquisitions and disposals, refinancings, restructurings and exits. We help our clients structure deals in a tax-efficient, compliant manner, taking into account the relevant domestic and cross-border tax rules and regulations, and the commercial and operational needs of the parties involved.

The tax implications of infrastructure transactions can have a significant impact on the value, feasibility and structure of a deal. Our world leading tax team has experience gained from advising sponsors and banks on some of the most high-profile and strategic infrastructure deals in the market. We help our clients navigate the tax complexities of infrastructure investments. We work to optimise their tax position in line with their commercial objectives and regulatory compliance. 

Real estate transactions can involve complex and innovative tax issues, especially when they cross borders or involve multiple parties and financing sources. Whether you are making equity investments, or financing real estate transactions involving banks or alternative lenders, you need expert tax and structuring advice to optimise your returns and minimise your risks. Our real estate tax team has the experience and commercial acumen to advise you on every aspect of your transactions.

Tax issues are critical in restructuring and insolvency situations. They can affect the viability of transactions and outcomes for stakeholders. Our experience in market-leading insolvency and restructuring transactions, as well as involvement in government-led consultation exercises in relation to tax and insolvency, gives us the expertise to provide effective and commercial tax advice in all types of restructuring and insolvency scenarios.  We advise on tax aspects of contingency planning, debt restructuring, distressed acquisitions and sales, credit bidding and out-of-court refinancing as well as formal insolvency processes.

Our global team of tax specialists support our clients in all sectors with their relationships with tax authorities, including investigations and dispute resolution. We have extensive experience advising on information requests, responding to enquiries, managing tax audits, transfer-pricing challenges, MAP and arbitration processes and of managing on-going relationships with local tax authorities. We also have a strong track record of successfully litigating tax cases before courts and tribunals, as well as negotiating settlements and resolutions with tax authorities.