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Managing overseas tax disputes

Jason Collins and Richard Dickman (Pinsent Masons) provide advice on how FTSE 100 companies can protect themselves from potential litigation.

A recent study by Thomson Reuters (see on.ft.com/2swxU82) suggested that FTSE 100 companies were involved in fewer disputes with HMRC but more with the tax authorities in the overseas jurisdictions in which they operate. Many of those disputes will be in jurisdictions where the engagement with the local tax authority and dispute resolution process is similar to that experienced with HMRC. In other jurisdictions a very different experience can be had.

Anyone who has had to deal with HMRC will know what to expect: a robust methodical forensic analysis of the issue. Any settlement will be principled and fact-based – ensuring that the right tax is charged in the right place at the right time. HMRC is also...

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