Corporate tax
are two partners and four associates in the corporate tax part of the team, which means that we get to do everything,” Kate enthuses. “At some other firms, because they have much larger tax teams, you tend to narrow your specialism but here you are able to experience huge variety – you can be doing a commercial negotiation one day and a close analysis of a difficult technical issue the next.” The team’s work can broadly be divided into the three types. The first and main type of work is transactional, which involves “the buying and selling of assets such as real estate or shares in companies.” Kate explains that “in these types of transaction, my role is to assess the tax consequences for the client and also negotiate the tax provisions in the contract dealing with the allocation of tax risk among the parties.” At senior associate level, there is more responsibility for “managing transactions day to day and working alongside a junior member of the team.” About 60% of her practice is made up of this kind of matter. “Pure advisory work” is the second type. “Clients frequently come to us with questions about the tax aspects of their strategic decisions,” she explains. “For example, when a client is planning how to organise and structure a group of companies, it will seek advice on the tax consequences.” The third, smaller, category is contentious work. These rarer cases involve the full spectrum of dispute resolution including, sometimes, full litigation between a client and HMRC when there is a disagreement about how much tax the former should pay. Differences of opinion on taxation are of course far from exclusive to tax lawyers. “This area is always topical because it is a big political issue and it is constantly changing,” Kate observes. “The government sets a new Budget every year, but in 2020 we have seen Rishi Sunak make a Summer Statement
Virtually all commercial transactions have tax implications. Corporate tax is thus an important practice area for any major law firm. Working in corporate tax involves advising on the most tax-efficient means of acquiring, selling or restructuring assets, negotiating and documenting the transaction, and ensuring the smooth completion of the deal. On the contentious side, corporate tax lawyers advise on all aspects of tax litigation and investigations, including negotiating with tax authorities. “I was an all-rounder at school, so when it came to choosing a degree subject at university, nothing that I had studied previously stood out as my best area,” says Kate Worthington on her route into law. She was on the lookout for something new and the well-rounded nature of a law degree presented itself as a natural fit. “It involves a range of skills and opens a number of career options,” she explains. “The variety suited me perfectly.” Kate completed her training contract at Lovells (now Hogan Lovells), then joined Lawrence Graham upon qualifying (the firm would later merge with Wragge & Co, which then itself merged to become today’s Gowling WLG). At four years’ qualified, she joined top City firm Stephenson Harwood. “I wanted to be part of a leading firm with a full-service offering,” she says on the reasons for her decision. “I had also developed a specialism in real estate tax and funds, two areas that Stephenson Harwood excels in, so it was a good match. I really enjoy working in tax law and because the tax team at the firm is so well regarded, I knew that I would have opportunities to do varied, high-quality work.” As well as the top clients – a mix of “corporate entities, alongside listed funds and individual business owners” – and legal expertise, the smaller size of the tax team is a key draw for ambitious tax lawyers. “At the moment there
For more firms that work in this practice area, please use the “Training contract regional indexes” starting on p197.
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