European Tax Awards

European Awards night

ot even the giants of European Awards were presented in 38 categories: ment to achieve the most effective tax rates football dared to clash with national tax firm of the year in 17 jurisdic- generally and in transactions have been some International Tax Review’s tions, including Austria, , of the issues which tax executives have had European Tax Awards this year. and Portugal for the first time; to deal with recently. The advisers who were InN 2005, some said the UEFA Champions’ national transfer-pricing firm of the year in able to provide them with the best strategies League final between Liverpool and AC 16 jurisdictions – Ireland does not have to cope with these challenges came out on in was overshadowed by transfer pricing rules - and five pan- top during the awards ceremony. International Tax Review’s inaugural awards European awards, including the trophy to The last five presentations of the evening on the same night at Claridge’s Hotel in the European tax firm of the year and the were for the most prestigious prizes. The prin- . In 2006, the magazine had the Editors’ Award, a new prize this year. cipal award, for the European tax firm of the evening to itself and welcomed more than 200 The European Court of Justice verdict in year, was presented to the firm which had the tax directors and advisers to the second staging Marks & Spencer and the reaction of mem- best strength in depth in its tax services and of the event at the same venue. The ceremony ber states to this and other critical ECJ deci- was widely represented throughout . was held to celebrate the fine work which sions; the continuing use of disclosure by The prize went to . Some of the international tax practitioners accomplished in many national tax authorities to close the tax highlights for the firm between February 2005 Europe in the previous 12 months or so. gap and pressure from company manage- and February 2006 included the Porsche bond

18 July/August 2006 www.internationaltaxreview.com European Tax Awards

brings out tax stars issue in , the creation and launch of a challenge to the UK tax authorities’ investiga- past 12 months have been noticeably busier risk capital entity by AXA Private Equity tive powers in connection with controlled-for- across our practice, reflecting the increase through mezzanine investments, which its eign-corporations legislation. Brannan is work- of M&A activity in the market place and French practice worked on and the demerger ing on the 3G VAT appeal, in which the higher volume of tax legislation.” of GUS’ interest in Burberry Group, a UK Linklaters is representing four out of five UK PricewaterhouseCoopers was another matter. The firm has 13 tax partners in mobile phone operators. The ECJ held a hear- firm to retain a 2005 prize in the European London and 29 in the rest of Europe. ing in the case in February this year. The liti- transfer pricing firm of the year category. Guy Brannan, the London-based global gation strengths of the tax team lie in Some of the firm’s most notable transfer head of Linklaters’ tax practice, accepted advice on M&A, corporate reorganizations pricing work in Europe over the last 12 the award. and structured finance transactions. months was for the division of an interna- Linklaters carried off another of the pan- Linklaters also won the national tax firm tional group with eight different European European awards, repeating its 2005 triumph of the year awards in France and Germany. locations and three manufacturing sites. It as European tax litigation firm of the year. “It is a great achievement to have won all helped the company set up a new business The firm’s contentious tax group continues to four of these awards, clearly demonstrating model under a principal business structure. be at the fore of critical tax litigation in our substantial expertise in international The identification of key entrepreneurial Europe. The group is advising Vodafone in its tax and tax litigation,” said Brannan. “The functions and a transfer pricing methodolo-

www.internationaltaxreview.com July/August 2006 19 European Tax Awards

Tax firm of the year Transfer pricing firm of the year Tax firm of the year

Austria Austria

Cerha Hempel Spiegelfeld Hlawati Deloitte Deloitte Freshfields Bruckhaus Deringer PricewaterhouseCoopers - WINNER Freshfields Bruckhaus Deringer Haarmann Huegel Wolf Theiss Liedekerke Wolters Waelbroeck & Kirkpatrick - WINNER KPMG Linklaters Wolf Theiss - WINNER Loyens & Loeff Jones Day Nauta Dutilh PricewaterhouseCoopers

gy which suit the industry as well as the HSBC Holdings, Texas Pacific Group, Editors’ Award was that a firm had to have OECD transfer pricing guidelines was just Goldman Sachs, Citigroup and Nortel. made a specific impact on tax in Europe some of the transfer pricing work involved. In London, the firm employs both US over the last 12 months. Dorsey & The US tax firm of the year in Europe and UK tax lawyers while Jean-Michel Tron Whitney, who won the award, were the award was for firms that were founded and is part of a team of four partners in Paris. lead in the Marks & Spencer case have their headquarters in the US and who Jan Meyers heads the tax practice. at the European Court of Justice, in which provide US tax advice in Europe. And the Daniel Weyde works in and Vania the judges decided on December 13 last winner this year was Cleary Gottlieb Steen Petrella in . year that taxpayers could offset their loss- & Hamilton. The firm’s clients include The requirement to win for the new es in one member state against their tax

Transfer pricing firm of the yearTax firm of the year Transfer pricing firm of the year

Belgium Denmark Denmark

Deloitte - WINNER Bech-Bruun Dragsted Deloitte KPMG Ernst & Young KPMG - WINNER PricewaterhouseCoopers KPMG PricewaterhouseCoopers Kromann Reumert Plesner Svane Grønborg - WINNER

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European Tax Awards

Tax firm of the year Transfer pricing firm of the year Tax firm of the year

Finland Finland France

Deloitte Deloitte Allen & Overy Ernst & Young Ernst & Young - WINNER Arsene Cabinet d'Avocats KPMG PricewaterhouseCoopers Bredin Prat PricewaterhouseCoopers Cleary Gottlieb Steen & Hamilton Roschier Holmberg - WINNER CMS Bureau Francis Lefebvre Landwell & Associés Linklaters - WINNER Shearman & Sterling

bill in another, under certain conditions. The award for national tax firm of the Greinecker and Friedrich Roedler are the The firm is also the test case in year in Austria went to Wolf Theiss, which leading lights in the practice. group litigation orders concerning thin has notable expertise in the structuring of Deloitte took the award for transfer capitalization, advance corporation tax and M&A deals and financial products, as well pricing in Belgium. Its practice has a num- franked investment income that have also as in the taxation of hybrid financial instru- ber of well-known advisers, such as Patrick reached the ECJ. ments and derivatives. Cauwenbergh, and serves clients from Twenty-eight different firms won the 33 PricewaterhouseCoopers won its first offices across the country. national awards for transfer pricing and tax award of the night when it became Austrian The national tax firm of the year in given out in 17 different countries. transfer pricing firm of the year. Herbert Belgium was Liedekerke Wolters

Transfer pricing firm of the yearTax firm of the year Transfer pricing firm of the year

France Germany Germany

Arsene Cabinet d'Avocats Allen & Overy Deloitte & Touche - WINNER CMS Bureau Francis Lefebvre - WINNER Ernst & Young Ernst & Young Deloitte Flick Gocke Schaumburg KPMG Ernst & Young PricewaterhouseCoopers Landwell & Associés Flick Gocke Schaumburg Freshfields Bruckhaus Deringer Linklaters - WINNER PricewaterhouseCoopers

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Tax firm of the year Tax firm of the year Transfer pricing firm of the year

Ireland Italy Italy

Arthur Cox Baker & McKenzie Ernst & Young A&L Goodbody Bonelli Erede Pappalardo - WINNER Fantozzi e Associati Deloitte Chiomenti Studio Legale Maisto e Associati - WINNER Ernst & Young Ernst & Young Vitali Romagnola Piccardi e Associati KPMG Fantozzi e Associati Matheson Ormsby Prentice - WINNER Gianni Origoni Grippo & Partners PricewaterhouseCoopers Maisto e Associati

Waelbroeck & Kirkpatrick. The firm advises Martin Nielsen are well known members of fer pricing in Finland. Its work, in spring on all aspects of tax law, including litigation. the firm’s practice. 2005, for a US manufacturer of medical Its sub-groups include income tax, real Plesner Svane Grønborg won the award supplies and equipment under audit in estate, insurance and financial products, prof- for Danish tax firm of the year. The tax Finland because the tax authorities were it-sharing plans and pension funds, and value- practice took part in a number of significant challenging the headquarter services pro- added tax The firm’s leading tax partners are corporate deals, working alongside the vided to the Finnish company by its Philippe Malherbe and Daniel Garabedian. firm’s M&A group, and worked extensively European headquarters company in France The best firm in Denmark for transfer on litigation at the National Tax Tribunal. and Finland’s deductibility of those servic- pricing last year was KPMG. Ria Falk and Ernst & Young took first place for trans- es, was important.

Tax firm of the yearTransfer pricing firm of the year Tax firm of the year

Luxembourg Luxembourg Netherlands

Allen & Overy Atoz Allen & Overy Arendt & Medernach Deloitte Baker & McKenzie Atoz - WINNER Ernst & Young De Brauw Blackstone Westbroek - WINNER Linklaters KPMG - WINNER Ernst & Young Loyens Winandy PricewaterhouseCoopers Freshfields Bruckhaus Deringer Loyens & Loeff

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Transfer pricing firm of the yearTax firm of the year Transfer pricing firm of the year

Netherlands Poland Poland

Baker & McKenzie - WINNER Baker & McKenzie - WINNER Baker & McKenzie Ernst & Young Dewey Ballantine Deloitte KPMG Meijburg & Co MDDP Ernst & Young LECG PricewaterhouseCoopers KPMG Transfer Pricing Associates Weil Gotshal & Manges MDDP - WINNER

The Finnish tax firm of the year was Francis Lefebvre. The practice is backed up tax department, which has one other part- Roschier Holmberg, which is noted for its by a dedicated team of economists that ner and five associates. excellent transactional work. Gunnar works with the lawyers on client matters. Deloitte added the transfer pricing firm Westerlund is the firm’s tax partner. The Linklaters took the French tax firm of of the year in Germany to its Belgian prize. practice has seven other fee earners com- the year award. The practice demonstrated Heinz-Klaus Kroppen, who leads the firm’s prising Specialist Counsel, Vesa Rasinaho, its all-round ability over the last 12 months German and European transfer-pricing and six associates. in advising clients on corporate and financ- practices, is a member of the EU Joint The award for transfer pricing firm of ing transactions, as well as litigation Transfer Pricing Forum. the year in France went to CMS Bureau Philippe Derouin is the main contact in the The national tax firm of the year award

Transfer pricing firm of the yearTax firm of the year Transfer pricing firm of the year

Russia Spain

Baker & McKenzie Baker & McKenzie Ashurst Deloitte Clifford Chance Baker & McKenzie Ernst & Young Cuatrecasas Garrigues - WINNER KPMG Freshfields Bruckhaus Deringer Landwell Pepeliaev Goltsblat & Partners Landwell PricewaterhouseCoopers - WINNER Garrigues - WINNER Uría & Menéndez

24 July/August 2006 www.internationaltaxreview.com European Tax Awards

Tax firm of the yearTransfer pricing firm of the year Tax firm of the year

Portugal Portugal Russia

Abreu Cardigos & Associados Deloitte - WINNER Baker & McKenzie Gonçalves Pereira Castelo Branco & Associados Xavier, Bernades Bragança Deloitte Linklaters Ernst & Young Morais Leitão Galvão Teles Soares da Silva KPMG PLMJ - WINNER Linklaters Pepeliaev Goltsblat & Partners PricewaterhouseCoopers - WINNER in Germany also went to Linklaters. The finance tax groups are in particular demand The firm has quickly established itself as firm has 18 tax partners and 30 associates from clients. “The success of MOP’s tax one of the leading firms in Italy for transfer spread around four cities. Its comprehensive practice has been built on the execution of pricing since it was founded in the early range of skills include advice on restructur- a clear market-led strategy, a commitment 1990s. The firm works with firms in other ing, privatization, litigation and VAT. to excellence and the calibre of our peo- countries to develop transfer-pricing strate- Matheson Ormsby Prentice, the Irish ple,” said Liam Quirke, managing partner of gies for their multinational clients, particu- tax firm of the year, played the lead tax the firm and head of the tax practice. larly in the pharmaceutical, computer and role in more than 200 international transac- The Italian transfer-pricing firm of the chemical industries. tions in Ireland. Its corporate tax and year, was, once again, Maisto e Associati. Bonelli Erede Pappalardo took the

Tax firm of the yearTransfer pricing firm of the year Tax firm of the year

Sweden Switzerland

Deloitte Ernst & Young - WINNER Baker & McKenzie Ernst & Young KPMG Ernst & Young Linklaters PricewaterhouseCoopers Homburger Mannheimer Swartling - WINNER Skeppsbron Skatt Lenz & Staehelin - WINNER PricewaterhouseCoopers Pestalozzi Lachenal Patry PricewaterhouseCoopers Tax Partner AG

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Transfer pricing firm of the yearTax firm of the year Transfer pricing firm of the year

Switzerland UK UK

Baker & McKenzie Allen & Overy Baker & McKenzie Ernst & Young Deloitte Deloitte - WINNER PricewaterhouseCoopers - WINNER Ernst & Young Ernst & Young Tax Partner AG Freshfields Bruckhaus Deringer - WINNER KPMG Transfer Pricing Associates PricewaterhouseCoopers Walder Wyss Linklaters PricewaterhouseCoopers

award for Italian tax firm of the year. pricing in the insurance industry. The winner of the award as Netherlands Andrea Silvestri, the partner in charge of Atoz scooped the award for tax firm of transfer pricing firm of the year fought off the tax practice, advises international the year in Luxembourg. In less than two some tough competition to win the prize. clients on US and Italian tax law, having years the firm has come from nowhere to Baker & McKenzie provides the whole worked in America earlier in his career. be a major player in the tax advice market range of transfer pricing services in the The transfer pricing firm of the year in Luxembourg. It works with clients on Netherlands, including audits, advance award in Luxembourg went to KPMG, international tax issues such as M&A, real pricing agreements, structuring and litiga- largely because of the reputation of estate, private equity, and intellectual prop- tion. Monique van Herksen, the practice Ruediger Jung and his work on transfer erty and royalty planning. leader, is also head of transfer pricing for

Editors’ Award European tax firm of the year

Dorsey & Whitney - WINNER Allen & Overy Baker & McKenzie Ernst & Young KPMG Linklaters - WINNER Loyens & Loeff PricewaterhouseCoopers Shearman & Sterling

26 July/August 2006 www.internationaltaxreview.com European Tax Awards

European transfer pricing firm of the year European tax litigation firm of the year US in Europe Award

Baker & McKenzie Baker & McKenzie Baker & McKenzie Deloitte Garrigues Cleary Gottlieb Steen & Hamilton - WINNER Ernst & Young Liedekerke Wolters Waelbroeck & Kirkpatrick Dewey Ballantine KPMG Linklaters - WINNER Skadden, Arps, Slate, Meagher & Flom PricewaterhouseCoopers - WINNER Mannheimer Swartling Weil Gotshal & Manges Transfer Pricing Associates Pepeliaev, Goltsblat & Partners Slaughter & May

Europe, the Middle East and Central . transfer pricing firm of the year and tax firm the Swiss transfer-pricing firm of the year, De Brauw Blackstone Westbroek took of the year was PricewaterhouseCoopers, provides comprehensive transfer-pricing the award for tax firm of the year in the which has the biggest practice in the country, services from offices in 15 Swiss cities. The Netherlands. The tax department works in consisting of 200 Russian and Western tax firm carried out significant work in 2005 teams dealing with M&A, finance and liti- specialists. Planning, structuring and transfer for a large international chemicals group gation. It has a strong focus on tax planning. pricing advice, planning and defence are just listed on the Swiss stock exchange, helping “We only started building De Brauw´s tax examples of the firm’s expertise. Its director it to introduce a management fee concept practice in 2004,” said Paul Sleurink, a tax of international tax services is Bill Henry. for centrally provided services and align the partner. “This award is clearly a recognition Another firm to win both awards in their management fee concept subsequently of the efforts of our entire team”. jurisdiction was Garrigues in Spain. Some of with a new principal structure. The Polish transfer pricing firm of the the more significant transactions the firm Armin Marti is a leading adviser in the year award went to MDDP, which is adept advised on in the last 12 months included the practice. at transfer pricing advice, particularly in the sale of AUNA’s cable and wireline telephony The winner of the award for tax firm of preparation of documentation. Renata subsidiaries to Grupo Corporativo ONO; the the year in Switzerland was Lenz & Dluska and Arkadiusz Zurawicki are leading creation of a new financial services venture Staehelin. It provides advice on most mat- specialists at the firm. between GE Capital and Caja de Ahorros del ters, such as financial services, M&A, litiga- Baker & McKenzie’s tax practice in Mediterráneo and the tender offer for 100% tion and planning. Leading partners in the Poland won the award for national tax firm of the Cortefiel’s capital stock. The tax prac- practice include Jean-Blaise Eckert, Henri of the year there. The firm provides com- tice has 520 members, including 74 partners. Torrione and Heini Ruedisuehli. prehensive advice on all international tax Ernst & Young won the Swedish trans- The dominant firm in transfer pricing at issues. One of its specialties is representing fer pricing firm of the year award. The firm the Awards were Deloitte. It won its fourth clients before the tax authorities and in the worked on the design, implementation and national transfer-pricing firm of the year Supreme Administrative Court. Slawomir documentation of a client’s transfer pricing award in the UK, where it is expert in Boruc leads the practice. policy. The work needed to provide a advice on documentation, defence, plan- The transfer pricing firm of the year in methodology that worked for all the mem- ning and thin capitalization. Chris Adams, Portugal was adjudged to be Deloitte. bers of the group’s supply chain and docu- Mark Atkinson, Ron Haigh, John Henshall Laurie Wiggins has a well-deserved reputa- mentation that complied with rules every- and Daniel O’Mahony are the leading lights tion in the practice. where the members were located. Jesper in the practice. PLMJ took the prize as national tax firm Solgaard is a leading adviser at the firm. Freshfields Bruckhaus Deringer, the of the year in Portugal. The firm advises on The Swedish tax firm of the year has an winner of the award as UK tax firm of the the whole range of international tax mat- all-round tax practice under the chairman- year, shone particularly strongly last year in ters, including transfer pricing and litiga- ship of Brita Munck-Persson. Mannheimer its work for financial services and private tion. Rogério Fernandes Ferreira, Nuno Swartling’s group is made up of six other equity clients. Some of its best work Cunha Barnabé and João Magalhães partners and 11 associates. It has specialists in included the acquisition by Close Brothers Ramalho stand out as experts in tax law. financial services, M&A and private equity. Group of Seydler, a specialist broker/deal- The winner of the awards in Russia for PricewaterhouseCoopers, the winner of er in Frankfurt.

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