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International tax disputes

Over the last decade, governments and revenue authorities have adopted an aggressive stance in relation to international tax matters. This has in part been driven by the ease with which businesses can now operate cross-border and this has resulted in the blurring of several previously accepted tax assumptions. It is expected that there may be further uncertainty in this area in the wake of the COVID-19 pandemic.

This frequently results in tax disputes with relevant revenue authorities. Often by virtue of the nature of international tax matters, disputes span multiple jurisdictions. We have seen instances of different tax authorities undertaking simultaneous tax audits and investigations of businesses in multiple jurisdictions, as well as more traditional disputes concerning transfer pricing and tax treaties.

We have observed a growing trend in challenges to discriminatory tax measures across multiple forums. While the traditional method of litigating tax disputes in domestic courts is still the most important method of tax dispute resolution, alternative methods (such as double tax treaty arbitrations, mediations, mutual agreement procedures, bilateral investment treaty arbitrations, WTO challenges, EU law challenges, etc.) are growing in importance (largely due to recent measures introduced by the OECD, the EU and domestic governments).

Our team has experience advising on all forms of international tax matters. Our tax disputes lawyers have an incredible depth of knowledge representing a broad range of clients in all courts and tribunals including the UK Supreme Court, the Supreme Court of the United States, the Italian Supreme Court, the Finnish Supreme Administrative Court and references to the Court of Justice of the European Union. The team advises on mainstream tax litigation, arbitrations, mediations, mutual agreement procedures, investigations, bilateral investment treaty challenges, world trade organization disputes and criminal tax matters.

Often complex, very large and headline making, our work is always driven by one common factor – strong, high quality client relationships and a desire to assist our clients in delivering their strategic objectives, wherever they may be in the world. Whatever your end goal, big or small – if it is important to you it is important to us.

We can assist you with the following:

  • Tax Litigation
  • Constitutional Challenges/Judicial Reviews
  • Criminal Tax Matters
  • Tax Audits
  • Tax Investigations
  • Exchange of Information Requests
  • Double Tax Treaty Disputes
  • Tax Directives Disputes
  • Tax Discrimination Claims
  • Tax Arbitrations
  • Tax Disputes under Bilateral Investment Treaties
  • Tax Mediation
  • Pre-emptive Discussions
  • Enforcement Actions and Asset Recovery
  • Customs Litigation
  • Managing Disclosure

Our recent international tax disputes experience includes advising:

  • a Japanese bank, in a landmark judicial review case against HMRC in the UK Court of Appeal in relation to the extent to which taxpayers can rely on HMRC published guidance
  • the Italian and Swiss subsidiaries of a US group in relation to the closure of a mediation procedure on disputes relating to transfer pricing and permanent establishment issues
  • a major airline company in relation to a landmark beneficial ownership dispute in Russia
  • an American web services provider in negotiations with the Jordanian Tax Department with respect to a complicated sales tax matter and successfully reaching a settlement on behalf of the client

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Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.