Skadden, Arps, Slate, Meagher & Flom LLP

Tax Controversy and Litigation

Partner

Patrick O’Gara leads Skadden’s London Tax Controversy Group. He advises on matters involving U.K. tax law, including international tax planning and dispute resolution, and has represented many of the world’s largest multinational groups.

Mr. O’Gara assists in developing and defending global and regional tax strategies and resolving high-stakes domestic and cross-border tax disputes in a number of sectors. He has significant experience handling tax matters related to innovation and intellectual property, cross-border financing, transfer pricing and supply chain restructuring, as well as mergers, acquisitions and joint ventures. He regularly counsels clients on structuring U.K. inbound and outbound investments, cross-border mergers, corporate redomiciliations and IPO planning.

In addition, Mr. O’Gara advises on the impact of U.K. and international tax policy developments, with a focus in recent years on OECD/Inclusive Framework Pillar Two rules and their implementation across a wide range of jurisdictions.

Mr. O’Gara also represents multinational clients in complex and contentious audits and disputes involving HM Revenue & Customs (HMRC). His sector experience spans financial services, digital services and technology, industrial and consumer goods, health care, pharmaceuticals, and oil and gas services. Mr. O’Gara has acted on the resolution of a broad range of disputes, including complex transfer pricing and permanent establishment matters. He has also settled a range of issues with HMRC regarding the U.K.’s diverted profits tax and challenges relating to the recharacterization of supply chain arrangements. In addition, Mr. O’Gara has assisted clients engaged in HMRC’s high-risk corporates programme and profit diversion compliance facility.

Mr. O’Gara advises extensively on U.K. and European tax and policy matters. His work includes developing and negotiating advance pricing agreements (APAs) and mutual agreement procedures (MAPs) with competent authorities in the U.K. and internationally.

Postgraduate Diploma in Legal Practice, Nottingham Law School, 2003 LL.B., King's College, London, 2002