Allen & Overy

"Work in this department is never straightforward and will certainly keep you thinking."

Joining the tax department as a trainee was rather daunting at first, especially as I realised just how little I knew about this area of law from law school.  Despite this I was made to feel very welcome and it wasn’t long before I was fully involved in the work and felt that I was making a positive contribution.

One of the tasks that I was given was to prepare a first draft of a tax deed in connection with an acquisition of a company by way of a share sale (i.e. the shares in the target company were being sold by the seller to the purchaser).  The purpose of a tax deed is to allocate the tax risk of any tax arising in the target company (for example corporation tax on the target’s profits) between the purchaser and the seller.  Having allocated the risk a the tax deed then seeks to exclude liability for tax in certain specified circumstances and to set limits on any claims made.

My starting point for this exercise was the A&O know-how system which gave me both a useful precedent to work from and extensive guidance notes to take me through the process.  Without these my work would have been impossible and I began to really appreciate the firm’s excellent know-how resources.  With a little perseverance, some discussions with my supervisor and a few hours thinking, I managed to produce a first draft, and felt quite a sense of achievement.

The stages that followed demonstrate the varied and challenging nature of work in this department.  Not only must the tax deed be negotiated with the other party’s solicitors, but its function must also be explained to the client to enable them to give their input to the negotiations and understand the effect of the agreement.  Explaining a complex document to a client, especially one who is short of time, is perhaps one of the harder parts of the job and requires good people skills as well as a detailed knowledge of the document, and the law. 

The fact that tax law is constantly changing, and the often complex nature of transactions at A&O, means that work in this department is never straightforward and will certainly keep you thinking.