Overview
James Ross advises clients on a broad range of international and domestic corporate/commercial tax issues, including corporate restructuring, transfer pricing and thin capitalisation, double tax treaty issues, corporate and structured finance projects, mergers and acquisitions, and management buyouts. He counsels US groups in the structuring of UK and European inbound investments, including in relation to redomiciliations and providing advice on technical issues in the context of revenue investigations and statutory audits. He is particularly adept at advising on intellectual property holding structures.
James also helps clients with employment tax issues (including the taxation of equity incentives), and tax aspects of private equity transactions. He has experience advising on the negotiation of the tax provisions of numerous mergers and acquisitions transactions.
Results
- Advised US-based multinationals on restructuring their British and European groups, and on the implementation of corporate redomiciliations and UK holding company structures
- Advised European-based multinationals on the establishment of functions and activities in the UK
- Advised multinational groups on structuring for optimising the management and holding of intellectual property
- Advised UK inbound investors on thin capitalisation, treaty relief and arbitrage issues and negotiating thin capitalisation agreements with Her Majesty’s (HM) Revenue and Customs
- Negotiated advance rulings with HM Revenue & Customs on the tax consequences of inward investment into the UK
- Advised clients on a number of international corporate restructurings, disposals and acquisitions
- Advised clients on investment management structures for funds
- Advising clients on appropriate responses to the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) initiative
Recognitions
- The Legal 500 UK 2012 to 2020, recommended in Corporate and Commercial: Corporate Tax
- World Tax and World Transfer Pricing 2013 to 2019
Community
- Bloomberg BNA Tax Treaties Analysis, editorial board
Credentials
Education
College of Law, London, LPC, 2000
College of Law, London, CPE, 1999
Jesus College, University of Oxford, 1997
Admissions
The Law Society of England and Wales, 2002
