Tax Disputes Podcast Series
Across the world, tax risk is on the rise. What does this mean for you? Our six-part podcast series answers that question with expert insights from G20 countries across six continents. We will explore the tax disputes landscapes in Brazil, the USA, Australia, India, Nigeria and France, and talk about major developments, tax authority attitudes, dispute resolution, criminalisation risk, the importance of your narrative and much more.
The series is hosted by our Head of Tax Knowledge, Zoe Andrews, and PSL Counsel, Tanja Velling, the co-hosts of our regular Tax News podcast (find the latest episode here). The co-heads and other members of our Tax Disputes practice will join Zoe and Tanja to speak to local experts.
Subscribe to our Tax News podcast show or our Horizon Scanning podcast show on your preferred podcast app to be notified of new episodes being released.
Episode 1 - Brazil
Dominic Robertson and Ricardo Bolan, respectively Co-Heads of Slaughter and May’s Tax Disputes Practice and Lefosse Advogados’ Tax Practice, join Zoe Andrews to discuss the highly litigious Brazilian tax environment. Companies rarely have less than ten ongoing disputes. To what extent is the environment improving through the introduction of a settlement process, legal reforms undertaken with a view to future OECD membership and the overhaul of Brazil’s complicated indirect tax system? Tune in to find out.
Find out more about the speakers below.
Dominic Robertson is the Co-Head of Slaughter and May’s Tax Disputes Practice. He has a broad corporate tax practice from advisory and transactional work to tax disputes. He supports clients from first engagement with the tax authority through to settlement or litigation. Dominic has worked on landmark cases on domestic and international tax matters. These include leading cases on the UK’s salaried members rules and the interpretation of the UK/US double tax treaty.
Ricardo Bolan is the Co-Head of Lefosse Advogados’ Tax Practice. He has extensive experience in Brazilian tax planning and consulting, taxation of international operations, corporate restructurings, M&A transactions, private equity, investment funds and capital markets transactions . He also acts in Brazilian administrative and judicial tax litigation.
Tax Disputes Series - Brazil podcast transcript
Episode 3 - Australia
Richard Jeens, Co-Head of Slaughter and May’s Tax Disputes Practice, and Angela Wood, National Practice Group Leader of Clayton Utz Tax Practice, join Tanja Velling to discuss the Australian Taxation Office’s approach to tax compliance for multinationals. What is a “high assurance” rating and what are the potential benefits? Does the ATO take into account a wider range of factors than HMRC when considering whether to settle a dispute? What does the PepsiCo decision mean for the ATO’s expansive definition of “royalties”? Listen to the podcast to find out.
Find out more about the speakers below.
Richard Jeens is the Co-Head of Slaughter and May’s Tax Disputes Practice. He brings experience from his broader, multi-jurisdictional commercial and public law disputes practice to support clients in all aspects of their tax disputes, including underlying technical issues, litigation tactics and broader representational risks and obligations, whether in an enquiry, before a court or tribunal or in achieving a binding settlement.
Angela Wood is the National Practice Group Leader of Clayton Utz Tax Practice. She is a tax controversy specialist, proactively managing and resolving disputes for multinational and large domestic corporates at all stages of Federal and State tax disputes, particularly in respect of transfer pricing and anti-avoidance matters. Angela also has deep tax litigation expertise in the both the Federal and High Court of Australia.
Tax Disputes Series - Australia podcast transcript
Episode 5 - Nigeria
Sarah Osprey, Partner in Slaughter and May's Tax Disputes Practice, and Lolade Ososami, Partner at Udo Udoma & Belo-Osagie, join Tanja Velling to discuss tax disputes in Nigeria. How do Nigerian tax disputes generally proceed? Should taxpayers continue to comply with the transfer pricing regulations although their validity is in question? How are plans for a tax amnesty likely to develop? Listen to the podcast to find out more about these and other topics.
Find out more about the speakers below.
Sarah Osprey is a Partner in Slaughter and May’s Tax Practice. In addition to her advisory and transactional work, Sarah has an active contentious tax practice, covering both domestic issues and international tax matters, such as State aid, Diverted Profits Tax and transfer pricing.
Lolade Ososami advises on the tax aspects of diverse commercial transactions in various sectors. She understands the legal and regulatory framework for international investment in Nigeria and advises on domestic and cross-border commercial transactions. She provides support to foreign investors, multi-national companies, small, medium-scale and large enterprises and high net-worth individuals. Lolade is ranked as a “Highly Regarded” Lawyer for General Corporate Tax and Transfer Pricing by the International Tax Review.
Episode 2 - USA
Dominic Robertson, Co-Head of Slaughter and May’s Tax Disputes Practice, and Clark Armitage, Transfer Pricing Advisor and Member at Caplin & Drysdale, join Tanja Velling to explore US tax disputes trends. How can you prepare as the IRS is looking to take cases to litigation? What avenues for early engagement are available? How is the US Supreme Court likely to decide Moore, a pending case that could call into question large swathes of the US tax system? Listen to this episode to find out more about these and other topics.
Find out more about the speakers below.
Dominic Robertson is the Co-Head of Slaughter and May’s Tax Disputes Practice. He has a broad corporate tax practice from advisory and transactional work to tax disputes. He supports clients from first engagement with the tax authority through to settlement or litigation. Dominic has worked on landmark cases on domestic and international tax matters. These include leading cases on the UK’s salaried members rules and the interpretation of the UK/US double tax treaty.
Clark Armitage is a Member in Caplin & Drysdale’s International Tax Group. Mr. Armitage's core practice is advising multinational corporations from a wide range of industries on transfer pricing matters, including planning, audits and appeals, advance pricing agreements (APAs), and Mutual Agreement Procedures (MAPs). Mr. Armitage also advises clients on a wide range of other U.S. international tax issues.
Tax Disputes Series - USA podcast transcript
Episode 4 - India
Sarah Osprey, Partner in Slaughter and May's Tax Disputes Practice, and Mukesh Butani, founder and managing partner of BMR Legal Advocates, join Zoe Andrews to explore India's tax disputes trends. Why is India's tax disputes landscape unique? What changes are taking place in India and why is Mukesh optimistic both about the use of advance pricing agreements (APAs) to mitigate tax risk and in terms of resolving disputes in India more generally? Listen to this episode to find out more about these and other topics.
Find out more about the speakers below.
Sarah Osprey is a Partner in Slaughter and May’s Tax Practice. In addition to her advisory and transactional work, Sarah has an active contentious tax practice, covering both domestic issues and international tax matters, such as State aid, Diverted Profits Tax and transfer pricing.
Mukesh is the founder and managing partner of BMR Legal Advocates, an international tax and transfer pricing boutique. He has over thirty years of experience advising multinationals and Indian conglomerates on matters relating to FDI policy, business reorganizations, cross-border tax structuring, and regulatory policy. He frequently speaks at global seminars and authors treatises and commentaries on international tax and policy.
Tax Disputes Series - India podcast transcript
Episode 6 - France
Charles Osborne, Partner in Slaughter and May's Tax Disputes practice, and Julien Gayral, Tax Partner at Bredin Prat, joined Zoe Andrews to discuss tax disputes trends in France.
What does the recent trend of criminalisation of transfer pricing matters in France mean for businesses operating in the country? What tools are tax authorities in France using to obtain information and to enforce the rules? What action can be taken to minimise French transfer pricing risk and what options are available to resolve disputes? Listen to the podcast to find out more about these and other topics.
Find out more about the speakers below.
Charles Osborne is a Partner in Slaughter and May’s Tax Practice. He regularly advises a variety of high-profile clients on tax consultancy matters, business transactions including public and private M&A, debt and equity markets transactions and group reorganisations, and contentious tax matters at both enquiry and litigation stages.
Julien Gayral is part of Bredin Prat's Tax team and practices in the field of French and international tax law. He has extensive experience in advising on the tax aspects of domestic and cross-border transactions (mergers and acquisitions, private equity and real estate transactions) and in handling tax controversy and dispute resolution. He also advises private clients, particularly corporate executives, on their personal tax situations.
