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Anna Burchner

Anna Burchner


CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English, Hungarian, German, Dutch

Anna Burchner is a partner in the Corporate Tax team at CMS UK.

She has experience in various areas of international tax with particular focus on funds, both in the regulated and unregulated sector. Her experience includes the structuring of fund products, listed and private funds (including venture capital), investments by funds and financial institutions, debt investments, group restructurings, M&A transactions, real estate investments and internationally mobile employees. She also has in depth experience in structuring investments into the UK and in transactional tax work, as well as transfer pricing projects

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Relevant experience

  • Takeda on its EUR 9.6bn acquisition of the Nycomed Group.
  • Coutts on tax risks of its cross border business in respect of over 60 overseas locations.
  • Commerzbank tax advice on structuring a French alternative fund with UK portfolio manager.
  • Riverside Company tax advice and structuring on the acquisition of the Fadata Group.
  • Structuring work for the Enterprise Innovation Fund (ENIF), where cornerstone investors are EBRD, EIF, KfW and Western Balkan governments.
  • Bouwfonds on due diligence and advice on the sale of a fund portfolio involving UK property.
  • Tax structuring advice on various inbound UK property (hotel) investments.
  • Willis Towers Watson on various fund investments, fund structuring, related FATCA and CRS matters.
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2005 - QLTT, College of Law
2002 - LL.M in International and European Tax Law, University of Leiden
2000 - Doctor of Law and Political Sciences, ELTE University Budapest

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CMS bol­sters Lon­don Tax of­fer­ing with part­ner pro­mo­tion
Pub­lic re­gister of ul­ti­mate own­ers of UK prop­erty
The UK Gov­ern­ment has re­cently an­nounced that a pub­lic re­gister of ul­ti­mate own­ers of over­seas en­tit­ies hold­ing in­terest in UK prop­erty will be re­leased by early 2021 (an­nounce­ment here). Lease­hold in­terests are pro­posed to be in scope where a lease is re­quired.
CMS ad­vises lis­ted Pol­ish house­hold ap­pli­ances com­pany,...
Eight jur­is­dic­tions leave the EU black­list
The European Coun­cil Code of Con­duct agreed on 23 Janu­ary 2018 to re­move eight (in­clud­ing Panama, South Korea and the UAE) of the ori­gin­al 17 jur­is­dic­tions lis­ted in the in­aug­ur­al EU tax haven black­list pub­lished on 5 Decem­ber 2017.
EU black­list of tax havens and plans for tax­ing the di­git­al eco­nomy
The EU black­list On 5 Decem­ber 2017, the European Coun­cil Code of Con­duct (“ECO­FIN”) pub­lished a black­list of 17 coun­tries named as tax havens (ac­cess the list here), for hav­ing failed to im­ple­ment ne­ces­sary meas­ures to tackle tax fraud, eva­sion and ag­gress­ive.
Tax­ing the Di­git­al Eco­nomy: first steps by the UK
HM Treas­ury has pub­lished a po­s­i­tion pa­per in re­spect of tax­ing the di­git­al eco­nomy (avail­able here) fol­low­ing the Chan­cel­lor’s Au­tumn Budget. The pa­per pro­poses that mul­tina­tion­al groups’ profits should be taxed where value is gen­er­ated.
Con­sulta­tion: UK Roy­al­ties Wi­thold­ing Taxes on pay­ments between non-UK...
As prom­ised in the Au­tumn Budget, the Gov­ern­ment has pub­lished its con­sulta­tion doc­u­ment on roy­al­ties with­hold­ing taxes (the “Con­sulta­tion”) (ac­cess here). The Con­sulta­tion as­sesses how the concept of with­hold­ing tax may be ap­plied to tackle in­tra-group ar­range­ments.
UK rat­i­fies the Mul­ti­lat­er­al In­stru­ment on BEPS
In the Au­tumn Budget, the Chan­cel­lor an­nounced that le­gis­la­tion will be in­cluded in the Fin­ance Bill 2017-2018 (the “Fin­ance Bill”) giv­ing ef­fect to the Mul­ti­lat­er­al Con­ven­tion to Im­ple­ment Tax Treaty Re­lated Meas­ures to Pre­vent Base Erosion and Profit Shift­ing.
EU Frame­work for resolv­ing double tax dis­putes
The EU Eco­nom­ic and Fin­an­cial Af­fairs Coun­cil has ad­op­ted a Dir­ect­ive to cre­ate a new sys­tem to re­solve double tax­a­tion dis­putes between EU Mem­ber States. This meas­ure will af­ford tax­pay­ers a trans­par­ent pro­cess with clear dead­lines ap­plic­able to tax au­thor­it­ies.
Pub­lic In­put on Tax­ing the Di­git­al Eco­nomy
The OECD has opened a con­sulta­tion on tax­ing the di­git­al eco­nomy (here). The dead­line for com­ments from the pub­lic is 13 Oc­to­ber 2017 and all com­ments re­ceived will be made pub­licly avail­able. A pub­lic con­sulta­tion meet­ing will be held on 1 Novem­ber 2017 at.
Europe Tax­ing the Di­git­al Eco­nomy: could a turnover tax be on the...
The European Com­mis­sion in a pa­per re­leased on 21 Septem­ber 2017 out­lined dif­fer­ent op­tions for tax­ing profits of di­git­al busi­nesses, to en­sure tax is paid where ‘value is cre­ated’ (ac­cess the press re­lease here).
Pub­lic Coun­try-by-Coun­try Re­port­ing; Tax­pay­er­s' Rights
Ap­pro­pri­ate Use of Coun­try-by-Coun­try Re­ports The OECD has now pub­lished Guid­ance (avail­able here) on the ap­pro­pri­ate use of Coun­try-by-Coun­try Re­ports (‘Cb­CRs’) by na­tion­al tax au­thor­it­ies. This is in re­sponse to some val­id MNE con­cerns that tax au­thor­it­ies.
Cur­rent BEPS Ac­tion Items for As­set Man­agers
For as­set man­agers in­clud­ing man­agers of Al­tern­at­ive In­vest­ment Funds ("AIFs") the Base Erosion and Profit Shift­ing pro­ject ("BEPS") is a par­tic­u­lar is­sue.   Many out­comes will likely af­fect this in­dustry, but those re­gard­ing per­man­ent es­tab­lish­ments ("PE"),.