Tax

Our global tax team regularly leads cross-jurisdictional teams working for multinational corporations on sophisticated projects that span multiple countries.

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Our global tax practice brings together over 140 dedicated lawyers and tax professionals, offering exceptional depth and breadth of expertise. We handle the most complex domestic and cross-border matters, delivering tailored solutions for our clients.

Our geographic reach is equally strong on both sides of the Atlantic, with tax practices in the U.S., UK, France, Germany, Spain, Luxembourg, Netherlands, Italy and Mexico.

We provide a balance of tax advisory and transactional tax advice to our clients in across key sectors, including Financial Institutions, Private Capital, Real Estate, Automotive, Life Sciences & Healthcare, Technology, Energy and Sports, Media & Entertainment.

Our tax advisory work covers structuring advice for multinational businesses; representation in tax disputes and controversy; design and implementation of employee incentives and benefits; and transfer pricing strategy and documentation. On the transactional side we provide tax advice on a wide range of corporate and finance transactions, including M&A transactions; financing structures and debt arrangements; real estate transactions and REITs; corporate restructurings; fund formations and private equity investments.

Our team also brings deep experience in specialist tax areas that are critical to today’s financial markets and corporate landscape. We advise on the tax aspects of securitizations and structured finance transactions, including CLOs, CMBS, RMBS, and other structured products. We regularly counsel clients on complex restructuring and bankruptcy‑related tax matters, helping them navigate distressed situations, debt modifications, and reorganizations. Our tax controversy practice represents clients in high‑stakes disputes with federal, state, and international tax authorities, including audits, administrative appeals, and litigation.

Our tax team is consistently highly ranked in the leading legal directories. We have numerous individuals acknowledged as market-leading experts, reflecting our commitment to excellence and innovation.

Structured Finance and Derivatives and Tax

International Tax Planning

Investment Funds and Tax

M&A and Tax

Real Estate Tax and REITS

Stamp Tax

Tax Audits

Tax Disputes and Controversy

Tax Exempt

Tax Legislation and Policy

Tax Valuation

VAT and Indirect Tax

Our tax team help debtors, creditors, equity stakeholders, buyers, sellers, and investors on restructurings and insolvencies, to ensure that tax is not adding to the pain. With global resources, we help you navigate the issues at play and develop an efficient strategy that works for you. So you can move forward with confidence.

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The capital markets can be a complicated place and with huge numbers at play, taxes can be crucial. The rate of change of tax law and introduction of new challenges can make other regulatory changes look slow. The complexity can be bewildering and knowledge of current market practice is often just as valuable as technical ability.

Our tax team can cut through these problems. We regularly work with leading international institutions to ensure their capital markets transactions run smoothly and without leaking tax.

Our planning is never approached in a tax vacuum. We work with our colleagues in corporate, commercial, regulatory, and IP to provide business-led solutions. We ensure that our planning is properly implemented with no disconnects and no risks.

We will help you throughout the life of your business. So whether you're expanding into new regions, starting new business lines, rationalizing your corporate structure, or looking at your financing, we can help you do it efficiently.

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Investors want to be in the same position -— if not better —- than if they invested directly in the underlying asset. But it's a highly complex area.

Our combined regulatory and tax experience across multiple jurisdictions means you have the advice you need at your fingertips. Our teams work collaboratively to give clients a seamless approach to their investment issues. And because we've worked with fund sponsors, managers, and investors, we always see the problem from all angles.

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Today's complex, global M&A transactions require a fast-thinking, fast-moving tax team. You need advisers who know your business and your goals. You need advisers whose extensive market experience does not make them afraid to think creatively, and our tax team can provide this. We know our markets and we invest in our client relationships, so when it comes time for that critical due diligence, the ever important deal structuring, those time-pressured negotiations, we have a running start. Not to mention pre-deal restructurings and post-deal opportunities. Our team can help you maximize your deal value across the globe.

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The real estate and REIT tax matters on your plate are increasingly complex, multijurisdictional and cross border. You need to keep up with recent reforms and best practices to stay competitive and cost-efficient.

Our tax advisers can work with you on these matters. We’re creative and bold, but always pragmatic. We help companies at the highest level, structuring the most tax-efficient real estate transactions, such as the formation, operation, and liquidation of REITs and UPREITs, a structure we pioneered. With our team, you can navigate real estate and REIT tax matters with confidence.

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Underestimate stamp and transfer taxes at your peril as they can be a very significant cost in many deals. The rules are becoming increasingly complex and the rates are only going up.

Take real estate transfer taxes. On complicated, direct, and indirect real estate transactions, transfer tax is a critical deal issue. We know real estate and we understand the issues that underpin transfer taxes, and working closely with our real estate team, we are one step ahead.

So whether you have a real estate, share, or business deal, we have the knowledge you need to navigate your way through the myriad of distinct local rules, avoiding unnecessary costs and keeping your deal process smooth.

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Across the globe clients ask us to help with tax audits, test their tax analysis and assist with analysis they can't easily do themselves. But they also value our wider skills: forensics, gathering and presenting evidence, thinking like the tax authority, challenging the authority when they are unfair or don't stick to the rules.

If an audit leads to a court or tribunal appeal, we will be by your side, but few do, and we're here to make sure that your audits don't.

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Tax authorities don't always agree with your carefully considered tax position. Sometimes they want you to do things you don't want to do. Sometimes they behave unfairly. Sometimes they get the law wrong or it is not enforceable. And sometimes there has just been a mistake that needs unwinding with minimal tax cost.

Our global team knows tax authorities and we know how to resolve problems. We know tax and from tax audits to Supreme Courts, we can help.

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Being tax exempt comes with opportunities, but also responsibilities and problems to solve. Understanding the nuances of your status is vital and our tax team can guide you through the maze. From the formation and operation of nonprofit tax-exempt entities to handling complex tax-exemption applications and dealing with tax authorities on audit and controversy matters, investigations, impact investing, sponsorships and monetization of IP, we can help.

We handle the tax-exempt considerations of restructurings, mergers, joint ventures, investments, and activities involving unrelated business income tax. We advise on compliance, compensation matters, intermediate sanctions, and how to expand your programs internationally. We give you the confidence to understand and handle complex tax issues, so you can focus on the bigger picture.

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Our tax legislation and policy lawyers help companies, government entities, investment funds, and trade associations across all industries. We have strong working relationships with government tax-writing committees and regulators and so understand the ins and outs of the tax legislative and regulatory process. Because we are experienced and knowledgeable technical tax practitioners our legislative and regulatory solutions work with existing tax regimes.

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Valuations are increasingly important in the tax world and key to many tax positions and transfer pricing analyses, as well as assessing potential value and risk. With the value of intangibles reaching new heights, the valuation exercise is becoming more complex and it's harder than ever to define intangibles and their contribution to the value chain.

With great value comes great risk. Whether your business is looking to support a position, assess its tax/TP risk, or planning to achieve better efficiencies, our experienced valuation team can help.

Our valuation, legal, tax, and TP knowledge, combined with our hands-on industry insight, will give you a fully customized solution that achieves results and minimizes risk.

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Our market-leading VAT team recognizes the power of VAT as a tax that needs a different perspective and that needs special consideration for those in VAT-exempt industries. It’s a tax that can be a headache for in-house tax directors and we can provide solutions for your VAT and indirect tax needs. We help you plan your transactions, enact your day-to-day business, deal with niggling disputes with tax authorities, or confidently take on the bigger litigation if needed. We offer workable solutions and our extensive experience means we are ready for whatever you can throw at us.

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Our capabilities at a glance

Judicial review wins

Ex-government policy advisors

Pieces of legislation changed

Key contacts

Elliot Weston

Partner

Elliot Weston

Partner

London

Meet the Tax team

Representative experience

McCormick & Company Inc on its US$45bn acquisition of Unilever's food division.

Serica Energy Plc on its acquisition of UK oil and gas assets and infrastructure from TotalEnergies.

Savills on the acquisition of Eastdil Secured for US$1.1bn.

J.P. Morgan on a securitization issued by Banca Agricola Popolare di Sicilia.

Brookfield Asset Management on the sale of a 49% stake in PD Ports to Pontegadea.

Oxford Ionics on its US$1.075bn sale to IonQ.

Dick's Sporting Goods on its acquisition of Foot Locker.

CVC on the acquisition of Superstruct alongside KKR.

JPMorgan on US$1.5bn cross-border structured finance transaction with Nissan’s financial services subsidiary in Mexico.

Shaftesbury PLC on its £5bn all-share merger with Capital & Counties Properties PLC.

National Space Company on the acquisition of UP42 Satellite Geospatial Data Company from Airbus.

Novartis on the sale of Advanced Accelerator Applications Molecular Imaging to Siemens Healthineers.

Clipper Logistics on its £1bn takeover by GXO Logistics.

Recordati on its acquisition of Enjaymo.

Myriad Genetics on reorganization of international business operations and sale of EndoPredict business.

Metro Bank PLC on sale of £2.5bn Residential Mortgage Portfolio to NatWest Group PLC.

AXA Health on its acquisition of Healthcare Business Solutions (UK) Limited.

Literacy Capital plc on its sale and re-invest into Velociti Solutions alongside CBPE.

Ares Management in its acquisition of stake in France SailGP Team.

Sony Music Entertainment (Japan) and Sony Pictures Entertainment in acquisition of stake in Peanuts Holdings LLC.

Awards and recognitions

Tier 2 - Tax: non-contentious tax

Legal 500 US

2023

Tier 3 - Tax: International tax

Legal 500 US

2023

Ranked - Tax, District of Columbia

Chambers USA

2023

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Tax

Our global tax team regularly leads cross-jurisdictional teams working for multinational corporations on sophisticated projects that span multiple countries.

Our global tax practice brings together over 140 dedicated lawyers and tax professionals, offering exceptional depth and breadth of expertise. We handle the most complex domestic and cross-border matters, delivering tailored solutions for our clients.

Explore our capabilities

Business Restructuring and Tax