Inversions: The trend turning transactional tax planning upside down

Matthew Gilleard

May 26 2014

Mention the word ‘inversion’ or ‘inverted’ and the first things likely to come to mind for most people are inverted commas – the most supercilious of the English language’s punctuation marks, looking down on regular commas from their lofty perch with scorn. Possibly La Pyramide Inversée at Le Louvre, too. But mention those words today and a tax efficient restructuring mechanism may also feature. Matthew Gilleard explores the inverted reality of this transactional trend.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Matthew Gilleard

Matthew Gilleard worked at ITR between 2010 and 2016

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Big four should clarify their AI strategies, or risk further talent losses

As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole

Sam Sholli, March 27 2026

Direct Tax

This week in tax: Survey shows widespread use of AI in tax, but strategy lacking

Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team

Sam Sholli, March 27 2026

Transfer Pricing

AI will power HMRC’s continued quest for TP revenue, advisers suggest

Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest

Sam Sholli, March 26 2026

Direct Tax

What Corporates Want India technical knowledge header

Clients laud Indian tax advisers’ technical knowledge amid legislative upheaval

Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found

Tom Baker, March 26 2026

Indirect Tax

Brazil’s tax reform: how the IBS impacts municipalities

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

Wesley Fragas, March 25 2026

Indirect Tax

‘Welcome clarification’: experts dissect CJEU loyalty programme VAT ruling

While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions

Sam Sholli, March 25 2026

Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

Brazilian MNEs struggling to align pillar two with domestic tax incentives

While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard

Sam Sholli, March 24 2026

Direct Tax

Guinevere Moore on balancing tax litigation with childcare and ‘paying it forward’

Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series

March 24 2026

Direct Tax

Clients considering US relocation following pillar two carve-out deal: Baker McKenzie

But partners at the firm admit that jumping ship to the US would not be as easy as some believe

Tom Baker, March 23 2026

Direct Tax

A taxing week: AI is reshaping capital flows and toppling the old tax order

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created

Teresa Owusu-Adjei, March 20 2026