Tax

The team integrates innovative tax structuring expertise with the highest quality advisory skills to give clients a comprehensive cross-border tax service.

Over 120 Linklaters tax experts worldwide advise on all aspects of cross-border advisory and transactional tax matters. Particular fields of expertise include M&A and joint ventures, capital raising, tax based and structured finance, as well as real estate and investment funds.

In tax disputes, the contentious tax team is renowned for its creative approach to tax litigation. In 2008, for the third year out of four, the team’s expertise was recognised by the award of the title ‘European Tax Litigation Firm of the Year’ at the International Tax Review Awards.

Recent tax transactions include advising:

  • Swiss Re on Europe-wide reorganisation of reinsurance business
  • IKB Deutsche Industriebank AG on the restructuring, capital increase, sale to Lone Star and all legal and tax issues in relation to the subprime crisis
  • Lloyds TSB on its recommended acquisition of HBOS by Scheme of Arrangement and the contemporaneous placing and open offer of Lloyds TSB equity and preference share capital, fully underwritten by HM Treasury
  • RBS on its rights Issue, the largest rights issue in history and HM Treasury Recapitalisation. The recapitalisation was the largest partial nationalisation of a major bank (with HM Treasury acquiring control)
  • RBS on the €71.1 billion consortium bid by RBS, Fortis and Banco Santander for ABN AMRO and the subsequent break-up of the ABN AMRO Group
  • Anglo American on its £2.5 billion demerger of Mondi and the listing of Mondi on the LSE and the JSE by way of dual listed company structure
  • ScottishPower on its £11.6 billion takeover by Iberdrola and Iberdrola’s subsequent €25 billion IPO of its renewable energy business
  • Xstrata Canada and Koniambo Nickel on the development and financing of the US$4.19 billion Koniambo mining and metallurgical project
  • Fortress on its acquisition of WOBA (Dresden) Vodafone on a significant challenge in the UK courts to the compatibility of the Controlled Foreign Companies rules with EU law