The Clifford Chance Tax Disputes team is arguably the most experienced in the city and is well-placed to provide comprehensive and practical advice across the range of tax disputes, tax compliance and tax controversies. We will help you to identify and deal with potential threats to your business across all the jurisdictions you operate in.
Taxpayers, particularly those operating across national borders, are facing an increasingly hostile and complex environment. Public interest in supposedly aggressive tax planning has led to political pressure on tax authorities to tackle perceived abuse and tax authorities utilise an increasingly wide range of artillery to pursue taxpayers and to plug the perceived "tax gap" wherever possible.
Unlike many competitors, we have offices with tax disputes expertise across the globe. Our teams are based principally in the UK, Europe, the US, and Hong Kong but we have also advised clients with respect to tax compliance and tax-related disputes arising in other jurisdictions, where we have particular expertise and experience in acting as an interface between clients and local counsel and bringing matters through to a successful conclusion.
We have particular expertise in the following areas:
- Tax litigation before national and international courts, specialist tax tribunals, the courts of appeal and the European Court of Justice;
- Corporation Tax and VAT disputes;
- Enforcement proceedings;
Negotiation and drafting of settlements with tax authorities (particularly on "big ticket"/high value matters);
- Cross-border disclosure requests from tax authorities;
- Arbitrations with a significant tax component;
- Advising clients on parliamentary and similar investigations;
- Management of overall tax risk;
- Cross-border issues including permanent establishments, employment;
- Advising on the negotiation of tax treaties or bilateral/multilateral trade agreements with a significant tax component, and tax treaty disputes;
- Lobbying revenue authorities on the formulation of tax legislation and guidelines.