Those who have sought a ruling from their national regulators on a specific and unusual tax matter will be aware that it is not always straight forward and often involves numerous lengthy discussions, many letters back and forth and takes several months, if not years, before the matter is finally settled. This becomes an even more arduous task if multiple jurisdictions are involved.
A rather complex issue arose over whether tax was payable in France for a client of Blick Rothenberg (London) due to an enquiry raised by the French authorities. This enquiry appeared to be technically and factually incorrect but payment of the amounts of French tax assessed would have been catastrophic to the client. Jacqueline Wolfovski and Dominique Ducrest from Exponens (Paris) were asked to assist from the French perspective and their involvement proved vital for getting the matter resolved. In addition, it was necessary to involve HMRC (Her Majesty’s Revenue and Customs) in the UK. HMRC’s viewpoint was to support the UK tax payer (and this protected tax already paid in the UK by the client) but this resulted in some debate and dealings between the International Division of HMRC in the UK and HMRC’s counterpart in France.
The team in London, comprising of Alan Pearce, Tim Shaw and Chris Shepherd, had been involved in the discussions throughout and made the approach to HMRC.
The ongoing debate took almost 3 years to solve but, to the particular delight of the client, a joint effort and continuous dedication and enthusiasm from tax experts of two BKR member firms resulted in the French authorities finally agreeing that there was no tax liability in France.
As with many incidences like this, connections between member firms, using the international links and expertise available within the association, results in an extremely happy client for a BKR member firm.