Client Services / Tax / Tax - London

Tax - London

“…first-rate international tax planning advice to a quality client base.  Clients praise the team for developing alternative opportunities and implementing complex and time-sensitive solutions.  The practice is particularly singled out for its timeliness…..” (Legal 500 2006)

Tax advisory, planning and implementation work form major components of our London tax practice.  Additionally, we support other practice groups within the Firm, including our Mergers and Acquisitions and Securitisation and Structured Finance groups, providing commercial advice and representation in an efficient, realistic and timely manner.

In delivering our tailored advice, we bring to our clients an important blend of experience, innovation and pragmatism, never losing sight of the context of the question.  We value our reputation for accessibility and responsiveness.  Such attributes are key to building the close client relationships which facilitate a complete understanding of the business need, enabling our service to realise its full potential.

Our team in London includes highly skilled partners and associates together with a senior director of taxes who joined us from a Top 4 accountancy firm to enable us to provide a truly integrated multi-disciplinary approach to the legal and financial planning requirements of the business community.  Through our involvement with several professional technical committees, we are in regular contact with senior HM Revenue & Customs officials, ensuring that we are always up to date with the latest legislative developments and tax authority thinking.   We are recognised by clients, peers and leading market commentators and directories for our strong practice based on sophisticated tax structuring projects and a solid, blue-chip client base.

We also benefit from forming part of one of the largest and most comprehensive law firm tax practices in the world.   Accordingly, we have an international outlook and play a pivotal role in the provision of the Firm’s seamless global tax services, working regularly with our colleagues in the US and Europe, and our many other international contacts, including the members of the McDermott Will & Emery International Tax Panel, a network of premier non-McDermott tax professionals in other jurisdictions around the world.   The members of the International Tax Panel have been selected based on years of experience of working together, and with the intention of providing clients with a service level consistent with that of McDermott Will & Emery when a project involves jurisdictions in which the firm does not operate its own offices.

We possess a broad range of UK and international capabilities, including:

 

  • International tax restructurings
  • Inward investment
  • Transfer pricing and thin capitalisation: advising on strategic planning and implementation for multinational groups
  • Double tax treaty matters
  • Intellectual Property: including advising multinationals seeking to locate their IP development functions or developing innovative ideas to IP licensing and structured sales
  • VAT and commercial transactions: particularly where there is an international element
  • E-business: including established and start-up businesses
  • Corporate transactions: including M&A, reconstructions and listings, joint ventures and buyouts
  • Structured finance: including securitisations and other asset finance transactions
  • Banking and capital markets: including loan facilities, bond issues and foreign exchange, derivatives and other financial instruments
  • Tax litigation: including negotiating with tax authorities and conducting litigation in the courts
  • Private capital tax planning

Our recent experience includes:

  • Advising a number of multinational clients on the implications of the international arbitrage rules introduced in 2005
  • Renewal of first APA under the UK’s transfer pricing regime for major US based pharmaceutical company
  • Advising a FTSE 100 international group on the worldwide restructuring of its multibillion dollar brand to maintain ownership protection and enhance brand value
  • Advising on the European restructuring of a US based heavy machinery group, including debt restructuring to achieve UK thin capitalisation targets, and fulfilment of US repatriation objectives
  • Advising one of the largest transport providers in Europe on restructuring their intellectual property portfolio
  • Advising the principal UK subsidiary of a global developer and supplier of multimedia computer games on successfully settling a Revenue enquiry into certain transfer pricing aspects of its UK operations 
  • Advising a major insurance and financial services provider in relation to withholding tax issues relating to its investment portfolio in the UK and Europe, and on the transfer pricing related issues raised by possible changes to functions carried out in the UK
  • Designing and implementing international cash management structures for a number of clients
  • Advising UBS AG on its tax appeal in relation to the application of the UK/Switzerland Double Tax Treaty, including the hearing before the Special Commissioners and the client’s successful appeal to the High Court.  The case continues. 

Contacts

Tax Client Services

McDermott Will & Emery

McDermott Will and Emery