17 October 2025Publication
VAT Insights - October 2025
A round up of the Simmons & Simmons insights on VAT developments over the last month.
A new phase of tax disputes globally
Managing and mitigating contentious tax risks has never been more complicated, or more important.
We're entering a new phase of tax disputes globally. This is shaped by intense pressure on national budgets, increasing sophistication of tax authorities, the global exchange of data, enhanced Revenue authority powers, and a growing desire to criminalise 'non-compliant behaviour.
Regulators are increasingly joined up with tax authorities and public scrutiny in the media has become the norm.
Clients praise our "very holistic approach which is distinctive" (Chambers & Partners 2020) and our "ability to think through alternative ways of [...] challenging the scenario" (Legal 500 2020).
How we can help
We understand that managing tax disputes successfully involves more than advising on the law. We're one of the very few law firms to have a truly dedicated contentious tax practice, with partners and associates focussed entirely on tax litigation and disputes work.
With a unique blend of lawyers, tax advisers, accountants, transfer pricing specialists, and economists, our team specialises in complex, high-value tax disputes and investigations for both national and international clients.
Our work covers:
- the full range of domestic and international tax matters
- civil or criminal tax investigations
- civil litigation concerning tax matters, and
- negligence claims against advisers.
We work seamlessly with our wider Litigation, Investigations, and Competition and Regulatory practices so that every base is covered, whether handling a transfer pricing inquiry or a deferred prosecution agreement. We excel at managing the whole lifecycle of a tax dispute with a clear strategy in mind.
Our thought leadership
Tax controversy webinar series: upcoming webinars
Our tax experts are hosting a series of 30-minute webinars. We want to help you and your business be alert and agile to adapt and seize opportunities.
Tax controversy webinar series: our podcasts
Why not listen to our recent tax controversy webinar series? We've turned them into podcasts for you to enjoy. They're available on our website or on your usual podcast app.
Our experience
Large multinational
Representing a large multinational in proceedings before the Tax Tribunal concerning the application of the UK unallowable purpose and transfer pricing rules to intragroup financing transactions.
Asset managers and investment banks
Acting for a group of 19 leading asset managers and investment banks against the Indian Government on the levy of minimum alternative tax on offshore investment funds with tax at the stake of $6bn USD.4
Multinational conglomerate
Acting for a multinational conglomerate against India on the enforcement of Indian tax assessments c.$7bn USD for the gain on disposal of its Indian business.
Key contacts
If you have any questions, contact a member of the Tax Disputes team for assistance:
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