Tax Liability Insurance

Brand Logo

In addition to W&I insurance policies VTS offers tax liability policies on a standalone basis.

Tax liability insurance protects the insured when the tax authority disagrees with a tax position taken by the insured.  The policy covers financial loss where the tax authority deems the taxpayer to have a greater tax liability than claimed by it.  Tax liability addresses a specific circumstance rather than providing general coverage as per our W&I insurance policies.

There are certain tax liabilities and transactions that fit with the use of tax liability insurance and which VTS would consider which include:

  • maintenance of operating losses and other tax attributes following a transaction;
  • transfer pricing;
  • tax treatment of reorganizations and recapitalizations;
  • capitalisation and debt versus equity analysis;
  • capital gain versus income treatment;
  • deductibility of expenses and capitalisation of expenses;
  • compensation and distributions; and
  • imposition of withholding taxes.

VTS requires tax risks to have an associated tax opinion and would not insure tax liability risks:

  • that do not have the required standard of tax opinion;
  • where there is an indefensible tax position such as caused by a lack of information;
  • relating to penalties arising from organisational errors such as late filing;
  • relating to tax avoidance or evasion; and
  • relating to commercially available tax schemes.

Volante Transaction Services LINES OF BUSINESS

THE Volante Transaction Services TEAM

Martin Larkman

Global Head

Volante Transaction Services

Biography

Martin Larkman

Global Head

Volante Transaction Services

Martin has a wealth of insurance, legal and commercial professional experience. Martin is a recognised transaction liability insurance sector expert with substantial M&A insurance experience having undertaken transactions across the globe and having created and led M&A underwriting teams for both boutique and global insurance institutions.  Martin brings significant commercial experience to the role of Global Head having been an executive director in companies across North America, Europe, UK and Asia Pacific.  Martin is an England and Wales law qualified solicitor who has practised law in Europe and Asia Pacific across both international and domestic markets. As a lawyer, Martin specialised in corporate M&A law and focussed on international transactional private equity work. Martin’s experience encompasses over 200 transactions and he has more than 17 years of M&A experience.

Return to Team

Shaun Reynolds

Regional Managing Director - ANZ

Volante Transaction Services

Biography

Shaun Reynolds

Regional Managing Director - ANZ

Volante Transaction Services

Shaun is the Regional Managing Director for Australia and New Zealand, based in Sydney. In addition to growing the ANZ business, Shaun will work on transactional liability risks with the VTS APAC team. Shaun has over 16 years M&A experience and for the last six and a half years Shaun has worked as a senior underwriter for AIG’s Asia Pacific M&A insurance team where he underwrote risks across ANZ and Asia.  Prior to that Shaun worked in top-tier law firms in Sydney and London (including Herbert Smith Freehills) and as in-house counsel with MNCs, including GlaxoSmithKline and Booz & Co.

Return to Team

Krzysztof Jagiello

Country Manager, Poland

Volante Transaction Services

Biography

Krzysztof Jagiello

Country Manager, Poland

Volante Transaction Services

Krzysztof joins us from Polish M&A market where he worked for the last 8 years as a transactional lawyer. Krzysztof is based in Warsaw, leading the CEE market for Volante and focusing on developing operations throughout the region.

Return to Team

Cristobal Silva

Underwriter, UK & Europe

Volante Transaction Services

Biography

Cristobal Silva

Underwriter, UK & Europe

Volante Transaction Services

Cristobal is based in London and joins Volante as an Underwriter within the VTS UK & Europe team. Originally a Chilean qualified lawyer, Cristobal brings over 8 years of international M&A experience to VTS.  Cristobal also has a Master of Laws (LLM) from King’s College London.

Return to Team