Daniel J.
Friel

Representation of numerous large multinational groups regarding the tax structuring of their international investment and finance requirements including numerous ‘inversion’ transactions for U.S. and non-US Groups.

Representation of a major sovereign wealth fund on numerous of its proposed cross-border Global investments.

Advising many UK and non-UK businesses on the implementation of cross-border tax structures, utilising tax treaty and domestic law benefits to obtain tax efficiencies.

Advising and drafting tax legislation for sovereign entities including the UK tax authorities on certain aspects of the interpretation of the U.S./UK double tax treaty and Qatar on its entire tax regime.

Acting for SABMiller on all of its major M&A transactions including its acquisition of Miller, Fosters, Peroni, its South American beer interests, together with all related financings, its Black empowerment transactions in South Africa, and advising it on various major tax disputes throughout the world but particularly in the U.S., the UK and South Africa.

Acting for Barclays Bank on numerous transactions including its numerous high profile M&A opportunities including its acquisition of the Woolwich, numerous assets managers, various of its high profile property transactions including its moves to Canary Wharf and numerous tax controversy matters.

Acting for Qatar Holding on numerous acquisitions including on its acquisition of the Harrods Group. 

Acting for ITV/Granada on the entire consolidation of the UK ITV franchise network and its satellite TV operations.

Acting for the Carlyle Group on many of its portfolio acquisitions and divestments in the UK and Europe.

Representation for a consortium consisting of the Canada Pension Plan Investment Board and Onex Corporation on its acquisition of Tomkins plc.

Acting for the ABI committee on the highly complex restructuring of Punch Taverns.

Acting for Aldersgate Investments on the sale of 49% of its Global Switch shares to a consortium for £2.4 billion with options to purchase the balance at a future date.

Advising Norsk Hydro ASA on the acquisition of Vale SA’s aluminium business.

Representation for a number of entities on a variety of international structured finance matters.

Advising many major listed UK companies on disputes with tax authorities.

Restructuring of an Icelandic bank, negotiations with tax authorities regarding loss availability.

Advising clients on contractual disputes involving tax — very extensive experience here including: SPA Tax Deed and Tax Warranty claims; Interest and Dividend Withholding Tax disputes with counterparties (and with tax authorities); WT disputes with tax authorities on contractual fees under Double Tax Treaties; tax disputes arising from Bilateral Investment Treaties; resolving "gross up" issues and problems; advising on the operation of SPA Tax Conduct provisions; a major mediation (post deal) regarding payments for group relief to Seller (ITV).