Practice area
International tax
Cross-border tax planning and structuring for mid-cap groups operating in the EU, the UK and the wider OECD perimeter.
Where we act
Most of our international tax work sits at the intersection of three recurring questions for a mid-cap group: where does the holding company belong; how is income allocated between the operating subsidiaries; and what does the next event (a sale, a refinancing, a step-up) cost in tax friction.
We work the full cycle: structuring the entities, agreeing the intra-group flows, documenting the substance, and defending the position when a tax authority asks about it three years later.
How we are organised
The practice is partner-led on every matter; senior associates handle the workstream end-to-end without a tier of juniors learning the file. We do not have a dedicated audit affiliation, so there is no referral pressure on which advice we give.
Typical engagements:
- Holding-company review and reorganisation
- Tax structuring of cross-border acquisitions
- Pillar Two impact assessment and IIR/UTPR forecasting
- BEPS Action 13 country-by-country reporting and master / local file preparation
- Interest deduction limitation modelling under ATAD
- Hybrid mismatch analysis and remediation
What we do not do
We do not advise on aggressive personal tax planning, and we do not take engagements where the chosen structure is obviously inconsistent with the underlying economic activity. We turn down work that does not fit the bench.