OA’s tax practice focuses on the design and defense of sophisticated tax structures in both domestic and cross-border transactions. We advise corporate groups, investors and high-net-worth individuals on the tax implications of investments, corporate reorganizations and financing arrangements.

Our international tax experience includes the structuring of holding and investment vehicles, the application of double taxation treaties, transfer pricing matters, controlled foreign corporation (CFC) analyses and non-resident taxation regimes. We conduct pre-transaction modelling to assess alternative structures and to align tax outcomes with the broader investment strategy.

Tax considerations often sit at the center of corporate transactions. In mergers and acquisitions, financing transactions and capital markets activities, we integrate tax analysis into the legal architecture of the deal. Transaction structures, financing models, dividend policies and exit scenarios are evaluated together to ensure that tax outcomes remain sustainable over time.

In tax audits and tax disputes, we represent clients throughout administrative and judicial proceedings. Our approach goes beyond developing defensive arguments — we build technically rigorous case strategies supported by financial analysis, commercial context and detailed evidentiary frameworks.

Our tax controversy practice also extends to customs and administrative tax disputes, including matters arising from public procurement processes and cross-border trade regulations. We represent clients in complex proceedings involving tax assessments, customs duties and regulatory sanctions, combining technical tax expertise with a deep understanding of administrative litigation procedures.

We also advise high-net-worth individuals and families on inheritance planning, cross-border wealth structuring and family asset governance. Our work includes the tax aspects of family offices, foundations and international holding structures designed to preserve and transfer wealth across generations.

Capabilities

• Tax controversy and tax litigation
• International tax structuring
• Cross-border investment structures
• Transfer pricing and CFC analysis
• Tax aspects of mergers and acquisitions
• Tax modelling in financing and capital markets transactions
• Tax audits and administrative proceedings
• Family wealth and inheritance tax planning