Tax compliance & controversy

What we do

We support in-house tax functions in two stages of the lifecycle that are both undersupplied by full-service firms: the ongoing compliance discipline that keeps a clean record across multiple jurisdictions, and the early-stage defence when one of those jurisdictions opens an enquiry.

Compliance support

• Annual filing review across the group, with a focus on the items that diverge between jurisdictions (intra-group flows, withholding tax positions, deferred-tax assets and liabilities)
• Pillar Two governance: scoping, designated filing entity, OECD GIR data preparation, jurisdiction-by-jurisdiction QDMTT review
• BEPS Action 13 country-by-country reporting governance
• DAC6 / EU mandatory disclosure scoping and reporting
• Substance-rules reporting in jurisdictions that require it (Cayman ES, BVI ES, Bermuda ES)

Controversy

Most of our controversy work starts as a routine information request that turns out not to be routine. We work alongside in-house tax to manage the disclosure scope, frame the position the group can defend, and decide whether the answer is technical (file a counter-argument and proceed to the next stage), procedural (push back on the scope of the request), or commercial (settle at a known cost rather than litigate).

We are not litigators of record. Where a matter reaches an administrative tribunal or court, we coordinate with local litigation counsel and stay on the substantive tax workstream.

Where we have current capability

EU member states, the UK, Switzerland, Singapore, the Cayman Islands and the BVI. For other jurisdictions we work with a network of local counsel under our coordination.