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Sub practice

Tax Litigation and Investigations

In the increasingly complex and international area of tax legislation and practice, Allen & Overy’s global team of experts supports businesses in the full range of high-end cross-border disputes and investigations.

Our advice on all aspects of corporate, commercial, VAT and finance tax is designed to avoid disputes, but we are ideally placed to provide support when, or even after, various issues with revenue authorities arise. 

A&O advises a broad range of clients on tax compliance and tax-related disputes and investigations, with particular experience of advising financial institutions. We handle litigation before national and international courts and specialist tax tribunals, including Corporation Tax and VAT disputes, and we liaise with tax authorities and advise on all issues associated with enforcement proceedings.

What sets us apart is our deep experience in handling cross-border transactions, with tax teams in our international offices enjoying strong relationships with local revenue authorities to support the smooth resolution of disputes for the benefit of all parties. 

News & insights

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Publications: 28 JULY 2021

Qualifying Asset Holding Companies (QAHCs): A new UK tax regime for alternative fund structures

On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures.  Although certain aspects have yet to be…

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Publications: 22 JULY 2021

OECD Pillars, the digital economy and minimum taxes

To date, 132 jurisdictions have committed to the OECD’s two-pillar plan to reform international tax rules, as set out in its statement of 1 July 2021.  Although the genesis of the proposed reforms…

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Publications: 21 JULY 2021

German administrative guidelines on cum/cum and securities transactions – A challenging revision of principles

The Federal Finance Ministry (BMF) circulated revisited guidelines regarding the allocation of economic ownership in cum/cum and securities transactions on 15 July 2021. These guidelines include some…

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Publications: 02 DECEMBER 2020

Tax structuring advice not protected by litigation privilege despite enquiry from French tax authority

Litigation privilege did not apply to tax restructuring advice prepared for a company by accountants following enquiries received from the French tax authority. Even where litigation can be said to be…

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Recognition

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