World Tax 2009 >

The demand for top-class international tax services around the world continues to be intense. Tax authorities are scrutinising taxpayers'affairs more and more intently. Officials in many countries are aware of the role their tax system can play in their economy's competitiveness. Others still see the relationship between tax collector and taxpayer as essentially adversarial. In fact, if there is a strong message from the World Tax 2009 research, it is that the aggressiveness of tax authorities is getting more and more pronounced.

They are using the increased amount of ransfer pricing regulations, to home in on corporations to get the taxes they feel they are owed. The network of tax treaties around the world is increasing. Courts are handing down judgements that have implications and influence in more than one state. Australia and Canada both produced significant transfer pricing judgements this year.

In the rest of the world, tax authorities are picking up on best practice from other countries and working hard to create even-handed, respected tax systems.

At a multinational level, the European commissioner for taxation and customs union looks like he will fail to table a legislative proposal in 2008 on a common consolidated corporate tax base from the working group researching the issue, as planned. The plan is most definitely on hold. While a core of countries, such as France, Germany and Italy, want to go forward with a common tax base, other economies are holding out. Denmark, Ireland and the UK feel that a common tax base, which the Commission claims is only about the harmonisation of rules, is set to bring about the harmonisation of rates. They are steadfast against any move in this direction, though they may not prevent any collaboration. Under EU legislation, a group of countries can move forward with a particular initiative according to the doctrine of enhanced cooperation.

A wealth of issues, all moving at a different pace. That's why tax executives need the expert advice of tax advisers and lawyers to help them structure their businesses in a tax efficient manner and to ensure their views are presented properly to legislators and the tax authorities. The tax department of a multinational company can not hope to stay aware of the capability of tax advice in every jurisdiction their business is represented.

It is in this context that International Tax Review presents World Tax 2009, its comprehensive guide to the world's leading tax firms and tax advisers. We hope it will help tax executives to secure the best advice for their situation.

Methodology

Eight International Tax Review researchers and journalists interviewed corporate tax directors and advisers by phone, e-mail and face-to-face to compile the tiers of leading firms and lists of leading individuals in World Tax 2009.

Each firm that was listed in last year's edition was interviewed, along with the leading firms in the jurisdictions World Tax 2009 was researching for the first time

The corporate interviewees were chosen from a representative sample of clients of the leading firms in the market. One of the questions we asked was: "Who is your primary adviser?" We clearly could not know this in advance so the representative sample could only be constructed after the interviews were completed. The objective of interviewing both advisers and tax executives was to get an opinion of tax advisers from their peers and their clients. No recommendation from any adviser for their own firm or their colleagues in that firm was taken into account. Firms could not pay to be included in the tiers or to have their individuals listed but were offered independently the opportunity to list their professional details for a fee only after the tiers were finalised.

Tiers of leading firms from 47 countries or territories have been included.

Unique rankings

This year, once again, leading individuals are highlighted in the text about their firm in the market commentaries on each country and territory, rather than being listed separately by specialism.

At the top end of the rankings are the firms which have the greatest depth of resources, experience, and range of specialisms. They are considered the best teams overall for tax advice in the country concerned. In cases where our research revealed it is difficult to distinguish between the quality of teams, such firms are grouped, in alphabetical order, in the same tier. The criteria for the rest of the tiers is published here. As much as we would like it to be, this cannot be an entirely objective exercise. The ultimate criterion has to be quality of work so that is likely to be the reason why one firm, though modest in numbers, may be in a tier that, on the face of it, appears to be beyond it.

The important point to note about the rankings is that all the firms listed have well-regarded tax individuals in their advisory teams.

Ralph Cunningham
Managing editor, International Tax Review