Our tax department is significantly the largest tax practice group amongst Irish law firms. In contrast to the tax departments of other Irish law firms, we operate primarily as a “front-end” service. Significantly more than half of our work is on transactions or advisory matters where our tax professionals have the sole or lead role. We also advise on the taxation aspects of transactions as part of a multi-disciplinary team with lawyers from other groups within the firm. We often act as special tax counsel in transactions where clients require specialised tax advice and are not comfortable using the tax department of their existing legal advisers. We do not provide Tax compliance services.
We are the only Irish law firm to have a dedicated international tax group, which advises on cross-border transactions in conjunction with legal and tax counsel from other jurisdictions, we have committed considerable resources to building and maintaining good relationships with these lawyers.
We advise many leading domestic and international corporations and financial institutions doing business in and through Ireland. We focus on the timely delivery and implementation of integrated leading edge tax advice. Our philosophy is “can do” – if there is a solution we will find it and it will be practicable and capable of being implemented.
We are the only Irish law firm to have Irish tax capability in the United States. In 2011, leading tax adviser John Ryan, was appointed head of the firm’s US offices. Since June 2011, John has been based in the firm's office in New York.
We are consistently ranked as the leading tax law firm in Ireland by the European Legal 500, Chambers Global, PLC Which Lawyer?, American Lawyer, Directors Tax Handbook, World Tax and International Tax Review.
Our Tax Group advises in relation to:
We advise leading Irish and international companies across all industries with respect to their inward investment into Ireland, international tax and cross-border planning, corporate reorganisations and restructurings, M&A, demergers, flotation’s, private equity and joint ventures.
We are the only law firm in Ireland with a significant transfer pricing practice. Examples of our work in this area include advising on the first transfer pricing adjustment completed under Irish law, the first multi-lateral transfer pricing adjustment completed under Irish law, and the ground-breaking claim by a non-treaty resident company to correlative relief under an Irish tax treaty. We acted for a number of US multinationals in connection with the judgment of the US Ninth Circuit Court of Appeal in Xilinx v CIR.
Our finance tax practice covers a broad spectrum of debt based work including banking, structured finance, securitisation, repackaging, debt capital markets, asset finance, project finance and derivatives.
In league tables published each year since 2005 by international financial publisher, Thomson Reuters , Matheson Ormsby Prentice was recognised as having advised more issuers of specialist debt securities in international debt issuance transactions than any other law firm in Europe.
We provide both contentious and advisory VAT advice. We act on a broad range of cases including appeals before the Appeal Commissioners, judicial review applications to the High Court, appeals to the Supreme Court and cases before the European courts. Contentious matters range from the establishment of the VAT treatment for invoice discounting and factoring in Ireland, the application of VAT to various property structures, the Customs Duty classification of internet security devices and the defending of claims for Customs Duty on withdrawal of GSP preference. On the advisory side, we advise on VAT compliance and structuring in a wide range of industries, including financial services, property, retail, travel agency, software and aerospace.
Although primarily focused on general corporate and finance related work, our tax department provides a full range of taxation advisory services to our many clients doing business in and through Ireland. This includes real estate taxation, where we act for various consortia of Irish investors in relation to acquisitions and disposals of commercial property portfolios, and also development and financing.
- Tax Controversy and Tax Litigation
We have extensive experience in conducting tax controversy work including Revenue negotiations and tax efficient dispute resolution. We have been involved in some recent high profile tax litigation in the High Court. Certain contentious tax work does not proceed to litigation.
- Irish Tax Capability in the United States
We are the only Irish law firm to have Irish tax capability in the United States. In June 2011, John Ryan, who is widely acknowledged as one of Ireland’s leading international tax advisers, re-located to the firm’s New York office. John has more than 20 years’ experience advising international companies doing business in and through Ireland. He leads a team of tax, corporate and financial services lawyers based in the firm’s US offices, which focuses on advising US companies and financial institutions doing business in and through Ireland.
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