International corporate tax
We work with some of the fastest growing and most exciting businesses in the world, but rapid growth, especially in a quickly changing international tax environment, can present complex challenges as well as opportunities. Our international corporate tax team includes Australia, Japan, Singapore, Luxembourg, Italy, US and UK qualified lawyers. Their extensive knowledge and experience will help to ensure your situation is made easier.
We have decades of experience in supporting start-up, growing and established businesses, and as a full-service firm we are able to take a holistic approach in assisting you. In an increasingly digital economy, managing intellectual property is a critical aspect of most businesses and we work with our intellectual property colleagues to do that in a tax-efficient way.
Our team regularly advise on the application of double taxation agreements.
Global advice across a range of sectorsWe work with clients across a range of sectors including retail, real estate, hedge and private equity funds (on both the buy and sell sides), fashion, technology, hospitality and luxury brands. It's a point of pride for our lawyers to 'speak your language' – by which we mean that we understand your industry and the broader climate in which you operate. We apply this real-world knowledge to find the most effective tax arrangements for your business.
Finally, our extensive experience means that whatever your situation, we will usually have seen something like it before. We can give insight into what the tax authorities will expect from you, and how similar businesses manage their arrangements around the world. Our practical advice will help you to manage challenges and take advantage of opportunities.
Bespoke Japanese logistic fund
Represented PAG on the structure of a bespoke Japanese logistic fund for the benefit of a North American real estate asset manager with a value of US$250 million.
Mpower Partners Fund
Represented Mpower Partners Fund, Japan's first environmental, social and governance focused global venture fund, on their launch
Multi-national insurance company
Representing as lead tax advisor to a multi-national insurance company on a proposed sponsored Asia-Pacific Real Estate Fund, which will be seeded with over 20 commercial buildings owned by the sponsor in Japan, China, Australia, Singapore and Hong Kong, valued at US$2 billion.
US Silicon Valley online game maker
Representing a leading US Silicon Valley online game maker in a tax controversy with the Japanese tax authority, of which took over the matter from the client's long-time Japan tax advisor, who advised the client to pay the multi-million dollar assessment, and continue to servie as the tax advisor.
UK fund manager
Assisted a UK fund manager on Italian tax issues relating to setting up and doing fund raising for a EU investment fund seeking to invest in EU renewable energy companies.
Argentinean hotel chain investment work
We provided thorough advice to an Argentinean hotel chain on tax optimizing its global structure for US investment and expansion. This included extensive pre-IPO planning, interim financing structuring, a review of the fund documents and the creation of convertible notes for a special class of investors.
Russian engineering firm
We represent a substantial Russian engineering business, recently advising on the international tax aspects of its group restructuring prior to IPO.
Aboitiz Equity Ventures
Lead tax advisor for one of Philippines’ largest listed MNC in its power, banking and financial services, food, land and infrastructure investments across Singapore, Philippines, Vietnam and Indonesia.
A Canadian museum
We acted in one of the largest will contests in the New York Surrogate's Court, on behalf of a Canadian museum. Multiple and conflicting wills were presented to the court, and the parties alleged incapacity, undue influence and legal malpractice. However we were able to negotiate a reformation of the will, including a favorable settlement for our client, which was accepted by the Court.
This Californian arbitration case, Marlene McCoy et al v US Bank, related to a family trust. The trust beneficiaries had made claims against the trust and sought to prevent our client, as trustee, from paying its own legal costs out of trust funds. Our San Diego team argued that the beneficiaries' demands were unreasonable and their order was denied on appeal.
Wooldridge v Wooldridge
Our lawyers brought the highest value Inheritance Act claim to date in Wooldridge v Wooldridge (2016). We were acting for a widow who sought to increase provision under her husband’s will after his death in a helicopter accident. The will had been “homemade”, written without legal advice, and our client felt that her husband had intended to leave her a greater share of his assets.
Beneficiaries of the K Trust
Acting for the adult beneficiaries in the matter of the K Trust with local advocates. The Guernsey Royal Court sanctioned removing a protector for the first time (following similar principles established in Jersey, where we acted, in the matter of the A Trust and the B Trust).
The UK "non-dom" regime
"Non-doms" have returned to the political spotlight.
In our series of articles we explore what the UK "non-dom" regime is, what it may look like in the future as a result of potential political change and the alternatives regimes available across the world.
Read our short articles below to find out more.
18 October 2023 | Article
Foreign gains to be subject to Hong Kong Profits Tax (Part 3) – further refinement to the foreign sourced income exemption (FSIE) regime in Hong Kong
5 October 2023 | Event
Seminar | Singapore funds for APAC fund strategies - legal and tax aspects | Tokyo
31 October 2022 | Article
Foreign gains to be subject to Hong Kong Profits Tax – a call for re-examination of investment holding structures
9 December 2019 | Article
Distributions from foreign opaque trusts: new tax rules for Italian beneficiaries
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