Dorsey & Whitney has one of the UK’s most respected Tax practices with extensive experience of UK and EU Direct and Indirect Tax matters, representing over 300 of the world’s leading multi-national corporations.
Our highly-skilled and dedicated tax practitioners provide a sophisticated and tailored service to clients involved in both contentious and non-contentious disputes. We have particular expertise in the fields of:
- Cross-Border Group Relief
- Transfer Pricing & Thin Cap
- International and domestic direct tax and VAT
- Tax investigations and litigation
- CFCs
- Tax-effective planning and structuring
We continue to secure superb results for our clients with several multi-million pound repayments obtained over the last few years both with and without the need to go to court.
Ranked Top for Tax Litigation 2008 to 2011 – Legal 500
“This excellent team provides comprehensive, all-round advice to a variety of high-profile clients” (Legal 500 UK, 2011)
“The ‘first-rate’ team has an unparalleled reputation when it comes to Group Litigation Orders (GLOs) and EU tax work.” (Legal 500, 2010).
Dorsey & Whitney “arguably enjoys the best contentious tax capability in the city” (Legal 500, 2009 edition)
Ranked Top for Contentious Tax 2008 to 2012 – Chambers UK
“This global firm has a superb reputation for handling big-ticket European and group litigation order matters.” (Chambers and Partners UK, 2012)
‘This outstanding contentious tax team is known for handling high-profile cases, and offers substantial expertise in challenging HMRC in group litigation matters.’ (Chambers, 2011)
“Consistently prevalent in high-profile cases, and excels in handling direct tax group actions against HMRC. … Phenomenal EU litigation expertise." (Chambers, 2010)
“Excellent, with an amazing ability to manage the most complex litigation” (Chambers, 2009)
The team practices in actions for the recovery of damages against UK revenue authorities for the imposition of taxes and duties incompatible with international treaty obligations such as the EU treaty or relevant double taxation conventions; general tax litigation; commercial litigation.
Representative Litigation
Selected as the lead and test case solicitor in almost all the current group litigation orders in the Chancery Division of the High Court of England and Wales in which multinational company groups challenge the lawfulness of various UK corporate tax imposts including:
- the ACT group litigation;
- the Loss Relief Group Litigation;
- the CFC and Dividend Group Litigation;
- the Thin Cap Group Litigation;
- the FII Group Litigation
Current representations in 2011 include:
- Pending in the UK Supreme Court: The Test Claimants in the FII Group Litigation (hearing February 2012);
- Pending in the Court of Justice of the European Union: C-35/11 The Test Claimants in the FII Group Litigation;
- Awaiting application for permission to appeal to the UK Supreme Court: The Test Claimants in the Thin Cap Group Litigation;
- Pending in the Court of Appeal: Marks and Spencer v HMRC (hearing June 2011);
- Pending in the High Court: Prudential v HMRC (awaiting judgment)
Dorsey & Whitney (Europe) LLP is Authorised and Regulated by the Solicitors Regulation Authority – SRA Number 554640