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Tax

We approach matters holistically and ensure that our tax advice, and any implementation, reflects the wider legal and commercial context. We bring real-time insights into trends, attitudes and legislative developments and provide advice that will stand the test of time.

Our integrated teams of tax, corporate, finance, regulatory and dispute resolution lawyers have a broad client base, spanning corporates, governments/sovereigns, funds and financial institutions. This results in a rounded approach and tailored, realistic, commercially-sound advice.

Our expertise and experience of advising on the tax aspects of corporate transactions is unrivalled. We frequently work on structuring domestic and cross-border M&A, joint ventures and demergers, as well as corporate reorganisations.

We regularly advise on the tax issues that are key to structuring domestic and cross-border investments, including for funds and financial investor clients.

Our team is known for structuring the most complex and challenging financial transactions, including regulatory capital and hybrid financing packages, structured bond transactions, rights issues, loan agreements and securitisations.

Our contentious tax group provides experienced advice and guidance at all stages of a potential dispute with a tax authority, or a third party, on a tax-related matter.

We support clients through a variety of business challenges, including advising on tax aspects of crisis management.

M&A, joint ventures and demergers

Our global tax team has advised on some of the most significant and complex cross-border mergers, acquisitions joint ventures of recent years, working with both “buy” and “sell” side clients. We have particular expertise in the use of demergers or spin-offs to divest non-core businesses; clients rely on our multi-disciplinary team to guide them through the particularly complex legal issues inherent to these transactions.

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Investment and funds

We regularly advise funds, investors and financial institutions at all stages of a fund and investment lifecycle. We bring together experts in tax, corporate, regulatory, finance and competition law to advise on aspects of domestic and cross-border fund and investment platform establishment, primary investments (including LBO transactions of different sizes and complexity, public-to-private transactions and refinancings) and all forms of exits, such as IPOs and secondary buyouts.

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Financial transactions

Our tax team provides tailored advice on all types of financial transactions, from vanilla loan agreements to complex securitisations, and regularly advises investment banks and issuer clients on major deals across the global capital markets. We confidently lead on the structuring of some of the most challenging and high-value transactions in the market, including regulatory capital and hybrid financing packages, structured bond transactions, rights issues and other novel methods of raising finance.

Contentious disputes

The number, complexity and scope of contentious disputes with tax authorities is increasing and an ever-greater number of clients are mindful of the possibility of tax litigation. Our tax team works closely with our dispute resolution lawyers to provide advice and guidance at all stages of a potential dispute, from an opinion on a filing position, to advice on responding to enquiries or requests for documents from the tax authority, to negotiation, settlement or, where appropriate, litigation. Our contentious work also extends to managing tax risk and compliance obligations in an increasingly challenging environment.

Crisis management

We draw upon experience from across our network to support clients through their most significant and, in some cases, high profile crises. We regularly advise on complex tax compliance and crisis management matters, help during dawn raids, provide efficient fact finding, represent in tax proceedings and proceedings brought by state prosecution authorities and coordinate individuals’ defence lawyers if required.

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Real estate

Tax is an important element in many real estate transactions and our tax experts work closely with our wider real estate and fund structuring teams. Our team regularly advises on upstream and downstream real estate transactions, including the acquisition of real estate companies and properties through REIFs and SICAFs.

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Trusts

The team often works on matters originating from the firm’s pre-eminent global corporate department, usually where a trust is part of the structure of a transaction or undertaking or a body of trustees is party to the transaction.

Individuals seek Linklaters’ expertise when setting up trusts and making wills or gifts. Trustees rely on the firm’s advice on making distributions and changing the terms of their trust. Charities consult the team if they want to alter their constitution or are unsure whether they can make a particular type of grant.

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