Tax

A team that bridges the gap between tax and legal advice

We make sense of complex tax systems, enabling you to do business more easily, manage your commercial risk and save money – wherever you are in the world.

Our tax lawyers integrate tax expertise with legal capability to unlock value for all our clients. Matched with a commitment to understand your business needs, the result is streamlined, practical, tax advice with a commercial underlay.

For the Asian Century, we have built the knowledge and resources to become the cross-border merger and acquisition (M&A) structuring experts for Asia – offering both bespoke solutions and tried, tested and streamlined ways to efficiently facilitate your income or capital flow and minimise your tax costs.

And, to help you move quickly and efficiently, we’ll leverage our strong relationships with local regulators and revenue authorities.

All of this means that, from the conception of any international deal, our tax lawyers look to share their insights and work with you to co-develop the deal structure. Their input, well before the legal ‘heavy lifting’ and drafting starts, allows you to test the market before investing in the deal yourself.

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Cross-sector tax experience

We advise clients in all sectors on tax law. Our recent work includes representing a German-based multinational joint venturing in China in relation to major tax audit litigation. Taking an innovative approach to issues around tax incentives and transfer pricing, our PRC tax team were successful in having the tax authority withdraw the challenges. This resulted in tax savings of more than RMB120 million for the client.

We also advised Telstra on the landmark National Broadband Network project, as well as the restructured deal, NBN Mark II. This project reshaped the telecommunications industry in Australia, with our tax team tackling the challenges of managing complex contractual risk allocations in a heavily regulated environment and preparing a complex private tax ruling on behalf of Telstra.

Our lawyers’ other tax experience includes advising:

  • Affinity Equity Partners on all aspects the successful purchase of a 35 per cent stake in the AUS$960 million Velocity Frequent Flyer programme – a  ground-breaking joint venture involving a complex trust arrangement and a requirement for the investment to be ‘financeable’ after completion
  • Universal Music Group (UMG) on its sale of the Parlophone Label Group to Warner Music Group for £487 million
  • Chevron Australia on transfer pricing issues in relation to the funding of its Australian LNG projects, including tax controversy and litigation support
  • Antin Infrastructure Partners on the structuring of its second fund, Antin Infrastructure Partners II, which has a unique structure combining UK, French and Luxembourg vehicles to satisfy investors’ requirements and to comply with, amongst others, Volcker Rule and AIFMD requirements – we also advised on the establishment and reorganisation of its UK manager group
  • The Chinese government competent authority as their sole legal counsel, to provide legal and tax advice in assessing FATCA (Foreign Account Tax Compliance Act) rules, its application in China and support in the IGA (intergovernmental agreement) negotiations
  • A Hollywood film production company on co-investment and co-filming projects in China, involving sophisticated China tax issues such as permanent establishment, taxes on distribution licensing and profit distribution scheme on worldwide receipts, and tax structuring for setting up the Chinese company’s joint ventures in the US
  • The Alain Afflelou Group on the refinancing of its existing debt package, implemented by high-yield bonds, comprising €365 million 5.625% of senior secured bonds and €75 million 7.875% senior bonds and including a super senior revolver credit of €30 million
  • Corpfin Capital on the acquisition of the Foster Tower in Madrid by an Emirates conglomerate –including advice on the tax due diligence, on tax planning for the lease by Bankia to an industrial conglomerate based in the Emirates, and on the sub-lease of the building.
"The team reacts well and has an in-depth understanding of our business and related issues."

Chambers

Our lawyers’ tax expertise includes:

Discover our latest insights into legal issues affecting your business

2020年10月12日,经济合作与发展组织(“OECD”)分别发布了关于“支柱一”和“支柱二”方案的蓝图报告(“支柱一蓝图报告”和“支柱二蓝图报告”,合称为“支柱蓝图报告”),向公众征询意见。通过该做法,OECD推后了其此前关于OECD成员国能在今年年底前达成全球技术性和政治性共识的期望。考虑到世界正聚焦于COVID-19及美国总统选举,这并不令人感到惊讶。

09 December 2020

2020年6月,美国决定“暂停”加入经济合作与发展组织(“OECD”)的支柱一和支柱二方案,该方案为OECD税基侵蚀与利润转移(BEPS)项目的“第二阶段”。尽管如此,OECD仍然强调,美国既未退出谈判,也没有停止磋商。这一事件及时提醒我们,对于实施OECD的支柱一和支柱二方案,还存在着一系列障碍。本文对相关方案进行了概述,并就在国家间无法达成共识的情况下推进这些方案的替代性方法展开了思考。

07 October 2020

On March 27, 2020, the United States President Donald Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

30 March 2020

The UAE Cabinet announced in a game changing move that onshore foreign ownership restrictions will be relaxed to allow for up to 100% foreign ownership.

22 May 2018

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