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Tax investigations and disputes

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Enhanced tax enforcement efforts, together with increased cooperation among government tax agencies, represent extraordinary challenges for multinational companies. Our global tax investigations and disputes practice assists clients in managing multi-jurisdictional tax investigations and compliance matters wherever they arise.

We have an extensive track record representing private and public companies in all stages of tax disputes, from managing audits and investigations, to handling administrative contests and litigating cases up to the highest appeals courts. We also advise on the tax implications of general commercial settlements on litigation and regulatory matters.

Our tax investigations and disputes lawyers combine significant knowledge of international regulation, industry sector knowledge, cross-disciplinary skills and on-the-ground resources, enabling us to provide clients with a ‘one-stop’ practical solution across the full range of tax disputes.

Our areas of work include

  • government audits, investigations and enforcement
  • tax disputes
  • criminal tax defence
  • transfer pricing
  • access to information and lawyer-client privilege
  • penalties and interest
  • internal investigations
  • tax return privacy
  • whistleblower defence
  • competent authority proceedings
  • voluntary disclosures and tax amnesty representation.

Our recent experience

  • Representing a publicly traded pharmaceutical company in US district court refund action in excess of US$470m regarding a transaction that involved complex financial products, international tax issues, economic substance, substance over form and the step transaction doctrine.
  • Representing an Australian residential property developer in an Australian Taxation Office funded test case in the Federal Court of Australia which related to valuation and methodology under Australia’s goods and services tax.
  • Representing the taxpayer, a special purpose leasing company within Lloyds Banking Group, in a successful first instance hearing in the First-Tier Tribunal. This was the first taxpayer victory in a ‘main purpose’ case for over 30 years.
  • Representing a publicly traded company under IRS examination and before IRS appeals with respect to proposed adjustments to withholding taxes, foreign tax credits, dual consolidated losses, and the Section 199 deduction for domestic production activities.
  • Representing an Australian water authority in court proceedings to determine if a charge was properly characterised as a fee for services or a tax.
  • Advising HSBC in litigation concerning the compatibility of the UK’s Stamp Duty Reserve Tax regime of American depositary receipts with EU law. This case led to significant repayments for HSBC and a number of corporate taxpayers, as well as Her Majesty’s Revenue and Customs changing its interpretation of the law to comply with the judgment.