Clients rely on the recognized technical strength and commercial experience of Freshfields’ global tax team for advice on the most complex cross-border transactions, contentious tax matters and strategic tax advisory issues.
Fast-paced changes in tax policy and legislation and increasingly litigious tax authorities mean businesses need a global view of tax strategies.
The Freshfields global tax team is known for consistently excellent technical ability, market-leading international credentials and commercial judgement. Our ‘strength in depth’ is particularly important in the current climate, with our clients continuing to grapple with unprecedented challenges in the tax space – including the rapidly evolving international tax framework (with wide-reaching changes on the horizon at both an OECD and EU level) and increasingly litigious tax authorities.
We advise financial institutions, funds and corporate entities from all sectors on the tax issues arising on their most difficult, and high-value, transactions, disputes and risk-management issues. Our tax specialists collaborate with other Freshfields teams, including our corporate, disputes, antitrust, financing and IP lawyers, to provide robust commercial solutions across borders, working seamlessly with the firm’s StrongerTogether partner law firms.
Recent client successes
Successfully arguing before the Spanish National High Court and Spanish Supreme Court that EU holding companies wholly owned by non-EU investors can benefit from the withholding tax exemption on Spanish-source dividends provided for by the Parent-Subsidiary Directive.
We advised throughout the entire administrative and judicial procedure. The case also established that the Spanish tax authorities carry the burden of proving that such holding companies are artificial and abusive in order to deny this tax exemption. Read more about the case in our blog post.
Advising House of HR (and its management) on the €1.4bn acquisition by Bain Capital Private Equity of a majority participation in the group.
This deal was the largest private equity deal in Belgian history, one of the biggest European private deals of all time in terms of number of shareholders, and one of the biggest private equity deals of 2022 in terms of enterprise value. The deal gave rise to a highly complex, cross-border taxation issues, with our Belgian, French, German and Dutch teams heavily involved.
Acting for the London Stock Exchange Group, among others, in challenging the EU Commission’s state aid decision addressed to the UK regarding its CFC rules.
Drawing on our multi-practice expertise, we represented LSEG in its intervention in the lead taxpayer case at both the European General Court and the CJEU. We have also supported clients in successfully dealing with the related UK domestic recovery process.
Advising Siemens Energy AG on all tax matters relating to the tender offer for Siemens Gamesa Renewables Energy SA, which was subsequently delisted and integrated.
We provided tax advice (with a particular focus on Germany, Spain, the Netherlands and US) on the tender offer itself, as well as the offer financing and complex integration measures post-delisting. Read more about the deal in our press announcement.
Advising AmerisourceBergen on the €1.3bn cash acquisition of PharmaLex.
Working closely with our colleagues specializing in corporate, antitrust and employment law matters, we provided German, UK and US tax advice on this complex, large and strategically important life sciences deal. Read more about the deal in our press announcement.
Awards & Recognitions
International Tax Review, EMEA Tax Awards 2023:
- UK Tax Disputes Firm of the Year,
- Impact Deal of the Year: advising Getir on the acquisition of food delivery app Gorillas;
- Impact Deal of the Year: advising ED&F Man Group on its corporate restructuring;
- Impact Deal of the Year: advising Haleon on its demerger from GSK and listing on the LSE; and
- Impact Deal of the Year: advising on the acquisition of T-Mobile Netherlands by an entity jointly controlled by funds advised by Apax Partners LLP and Warburg Pincus LLC
International Tax Review, EMEA Tax Awards 2022:
- UK Tax Firm of the Year
- Tax Litigation & Disputes Rising Star award – Daan van Schaik
- Impact Deal of the Year: Cambridge Quantum Computing acquisition of Honeywell Quantum Solutions
- Impact Deal of the Year: Euronext acquisition of Borsa Italiana
"The team at Freshfields has excellent judgement skills, clarity of thought and analysis."
"Their expertise is excellent. They have exceptional attention to detail and are highly responsive."
"Renowned as a key player in major tax matters on behalf of its impressive client base” and “[s]tands out for its ability to advise on cross-border tax issues."