By their nature, financial transactions can give rise to complex tax issues, often on a cross-border basis as financial capital moves across boundaries. 

We act for banks and other financial institutions, financial intermediaries, borrowers and counterparties, to cut through the tax issues on transactions ranging from domestic bank lending to complex cross-border structured financings.  

We act on bank lending transactions, real estate and infrastructure finance, projects, asset finance, debt capital market transactions, securitizations and derivatives, advising  in relation to: 

•  the tax-deductibility of payments,  
• the tax treatment of income for banks and their branches, 
• withholding taxes (including FATCA),   
• the use of onshore and offshore securitization vehicles, and the availability of applicable special tax regimes, 
• tax treaty interpretation,  
• the application of “anti-hybrid” rules ,  
• the bank levy,   
• VAT,  
• stamp taxes and other indirect taxes  

We also advise our financial institution clients in relation to mergers, acquisitions and reorganizations, recapitalizations and tax elections, as well on tax governance and risk issues, tax audits and the managing of tax disputes.