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Sub practice

Tax Disputes

In the increasingly complex and international area of tax legislation and practice, our team of global tax disputes experts can successfully support your business.

Our experience in all aspects of corporate, commercial, VAT and finance tax is designed to avoid disputes arising, however, we are often called upon to advise when, or even after, various schemes or transactions have completed and issues with the revenue authorities have arisen.

One area which distinguishes us from our competitors is the handling of cross-border transactions. The proliferation of tax disputes, which often involve one or more jurisdictions, is where we can bring clarity of focus. It is the strength of our tax teams in international offices and their relationships with local revenue authorities which has allowed clarity and transparency to solve disputes to the benefit of all parties. This same strength also allows us to build structures to take advantage of benign tax treatment in certain countries to produce innovative solutions for clients.

News & insights

Publications: 26 FEBRUARY 2020

New OECD Guidance on transfer pricing aspects of financial transactions and main take-aways for Luxembourg

On 11 February 2020, the Organisation for Economic Co-operation and Development (“OECD”) published the “Transfer Pricing Guidance on Financial Transactions” (the “Report”). 

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Publications: 26 FEBRUARY 2020

New OECD Guidance on transfer pricing aspects of financial transactions

On 11 February 2020, the Organisation for Economic Co-operation and Development (“OECD”) published the “Transfer Pricing Guidance on Financial Transactions” (the “Report”). 

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LGBT

Publications: 26 NOVEMBER 2018

Latest Directors’ liability survey points to cyber and data loss as top risks facing senior managers

Allen & Overy, in conjunction with Willis Towers Watson, the global risk advisory and insurance broker, has launched its sixth annual Directors’ liability report – “D&O: Personal Exposure to Global Risk” – which outlines the changing risk culture affecting senior management.

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Publications: 27 MARCH 2018

No litigation privilege for controller of litigation under conduct of claims clause

A non-party to proceedings cannot claim litigation privilege, even if it is exercising rights to control litigation under a ‘conduct of claims’ clause in a share purchase agreement. Sellers exercising a right to control a third party claim will need to be aware that any documents generated for that claim are unlikely to be protected by litigation privilege as against the buyer in any separate litigation between the buyer and seller (eg under an indemnity contained in the share purchase agreement): (1) Minera Las Bambas SA (2) MMG Swiss Finance AG v (1) Glencore Queensland Ltd (2) Glencore South America Ltd (3) Glencore International AG, [2018] EWHC 286 (Comm), 21 February 2018

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