Caroline Brown

As a Legal Director in Bird & Bird's international Tax Group, I have particular strength on advising on international VAT matters, with in-depth experience on managing a wide range of VAT matters for multinationals and in working with colleagues in various jurisdictions to help clients address differences in local requirements.

Bird & Bird LLP offers an extensive team of specialists in international VAT and my practice represents advising a unique blend of clients in the UK and international markets. I have in-depth industry experience of advising on complex VAT issues and identifying related customs duty issues in connection with cross border client supply chains and commercial transactions, working frequently and closely with my colleagues from our international VAT and our Trade & Customs Groups, most notably for businesses in the aviation, e-commerce, retail and technology sectors, as well as providing transactional and advisory support for corporate M&A transactions.

The rapid growth in e-commerce and its impact on the collection of VAT on supplies in the market jurisdiction was identified as a key tax challenge in the context of the OECD/G20 nations' project on BEPs. As a result, today, the indirect tax treatment of cross-border supplies in goods and services is facing an incredibly ambitious and significant overhaul in Europe and elsewhere, with particular emphasis on ensuring taxation in the state of consumption. These changes are being implemented over the next 2-3 years as promoted by the EU's Action Plan on VAT and the OECD's International VAT/GST guidelines and building upon the recommendations in the BEPs project. These proposals not only target internet sales to consumers by online operators but will also impact cross-border trade more generally between businesses as well as through platforms. This affects so many of our core business sector clients who have to also face future changes in processes due to the UK's proposed exit from the EU's single market. I regularly advise our sector clients to help aid their understanding of local technical issues and options open to them as well as on the impact of future developments. I also frequently support our International Tax Disputes practice on international VAT advisory and compliance matters, helping clients to identify different strategies and solutions in successfully responding to tax authority challenges.

I joined Bird & Bird as a trainee and qualified in 2005. I am a member of the Chartered Institute of Taxation and a contributor to VAT chapters of various publications, including the Franchise Law Review, Practical Law Digital Business Global Guide (UK), Internet Law and Regulation (Graham Smith), and Internet Business, Commerce and Tax (Julian Hickey).

• Example experience includes advising multinationals on complex VAT issues in respect of international movements/acquisitions/disposals of high value assets (aircraft parts, satellites, railway equipment, precious metals), provision of innovative VAT structuring advice for a global engine leasing business in relation to its worldwide asset restructuring of a securitisation trust, advice to major aviation businesses in connection with acquisitions or transfers within Europe, and related leasing transactions, international VAT advice to an industry leading business in respect of their cross-border distribution of stored value gift and prepaid products, and commercial VAT advice for a major health sector outsourcing.