We creatively re-design groups’ inter-company trading and transfer pricing models to best suit commercial and fiscal constraints. Working with many of the largest law and accounting firms we have effectively delivered projects in the digital, consumer, medical, and financial sectors. Working alongside other business service groups allows us to minimise the trade-off between competing commercial and tax constraints.
We help clients resolve disputes. Recent experience includes transfer pricing, diverted profits tax, payroll issues, and debt. The key is to differentiate between what can be resolved through developing a common understanding of the most important facts and what differences can only be resolved through litigation. Thoughtful legal analysis and carefully focusing on procedural law are important in moving disputes forward.
We have represented clients before the First-tier and Upper Tier tax tribunals and the Court of Appeal. Similarly, we work with the most eminent QC’s.
We help clients re-think their approach to transfer pricing and valuation analysis relating to both assets and debt. The key is correctly analysing the transaction or asset being valued and the legal assumptions underpinning it. We team with leading valuation consultants and independent experts to support values used whether in a planning or dispute context. We have advised on valuation matters in the billions and are leading a number of complex pricing disputes.
Many clients risk significant extra tax and double tax as a result of unilateral and multi-lateral initiatives around digital taxation. We are supporting clients who wish to constructively engage with the OECD to promote workable and fair multi-lateral policies.