Tax

We have a market leading tax practice, consistently ranked as Tier 1 by all tax and legal directories. Our tax team works with many of the world’s leading corporates and financial institutions, providing the broad spectrum of Irish taxation advisory, dispute and transactional services.

Our tax advisory work has included advising on big-ticket M&A transactions, tax planning (principally with an international dimension) and financial services. We also regularly act as special tax counsel to clients on specialist mandates requiring sophisticated tax advice.

A significant part of our practice is in the area of contentious tax and tax disputes. We represent clients in all phases of tax disputes and have acted on some of the most high profile tax disputes in the Irish market.

We also have significant experience in the area of transfer pricing. This ranges from supply chain planning to engagement with the transfer pricing branch of the Irish Competent Authority (in connection with both MAP and APA matters).

Our tax group is actively involved, through various industry bodies, in the development of Ireland’s tax policy and implementation of OECD and EU initiatives relating to tax. We have also actively participated in governmental consultation processes, which have led to changes in Ireland’s tax laws.

The nature of our work is such that much of it cannot be publicly disclosed. We have however included a sample of representative matters below.

Our service portfolio includes:

  • Company mergers and acquisitions and strategic investments
  • Corporate reorganisations and restructurings
  • Corporate migrations
  • Corporate investment into Ireland
  • Private equity and hedge fund transactions and structures
  • Capital markets and structured finance
  • Asset and project financing
  • Securitisation
  • Investment funds
  • International tax and cross-border planning
  • Tax disclosures and tax reporting obligations
  • Real estate finance, structures and transactions
  • Transfer pricing
  • Tax litigation and revenue powers

Experience

  • ICON

    on its $12bn acquisition of PRA Health Sciences.

  • US Pharma Group

    representing and advising with respect to judicial review proceedings before the Irish High Court and a TAC appeal concerning a tax assessment associated with a disposal of IP rights.

  • Endo International

    on its successful exit from a US Chapter 11 restructuring.

  • Ulster Bank

    on the sale of approximately €4.2bn of assets comprising of large corporate and commercial loans to AIB.

  • AIG

    and its subsidiary, Corebridge Financial, on the sale of Laya Healthcare Limited to AXA for €650m.

  • Mountpark Logistics EU S.a.r.l

    in respect of the €225M sale of Irish real estate holding companies.

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