Cross-border M&A

What we do

We act as tax-led deal counsel on cross-border transactions in the USD 50m–500m enterprise-value range. Most of our matters come in two flavours: strategic buyers acquiring a mid-cap target in a regulated sector, and founder-owned groups selling to a financial sponsor.

The recurring work on our side of the table:

• Pre-signing tax structuring of the acquisition vehicle and the funding stack
• Tax due diligence, with a focus on the items that survive completion (transfer pricing, withholding tax exposure, permanent establishment risk in third countries)
• Negotiation of tax warranties and indemnities, and of the W&I policy exclusions that follow from them
• Post-closing integration: tax-efficient debt push-down, repatriation paths, IP migration, holding-company consolidation
• Tax-led carve-outs of business lines from larger groups

How we work with deal counsel

We are typically engaged alongside an M&A firm of record. Our scope is the tax workstream end-to-end; we coordinate with corporate, finance and antitrust counsel rather than competing on those workstreams. This gives us a narrower, deeper role and avoids the bill-padding that full-service mandates usually drag in.

What we will not do

We will not take a mandate where the acquisition structure is obviously inconsistent with the operating posture post-closing, or where the tax planning hinges on a position that we expect to lose on audit within three years.