Euclid Transactional
Turning Tax Uncertainty into Commercial Certainty

Chris Waddington, Managing Director and Head of EMEA Tax, Wai Ling Low, SVP, APAC Tax and Justin Berutich, Executive Director, Head of Tax

A defensible tax position does not always make a decision easy. The uncertainty over how much a challenge could ultimately cost can be enough to slow a transaction, complicate a restructuring or put a valuable opportunity on hold. Tax liability insurance can transfer the financial consequence of that uncertainty, giving businesses greater confidence to proceed with a supportable position. Its value, however, is not limited to shifting the risk. The right policy converts an open-ended exposure into a defined, quantifiable cost, which can make a difficult commercial decision materially easier to approve.

That is the lens Euclid Transactional brings to each matter. Named Tax Liability Insurance Company of the Year in back-to-back years, for 2025 and again for 2026, the firm has applied that approach consistently as its practice has scaled. It provides bespoke tax liability insurance to private equity firms, multinational corporations, institutional investors, family offices and other sophisticated taxpayers. The starting point is not the insurance policy but what the client is trying to accomplish. That commercial mindset keeps the underwriting focused on the decision the client needs to make, rather than treating the tax position in isolation. Euclid considers the facts, applicable law, existing advice, potential exposure, timing and the interests of the parties involved before determining how the risk should be covered. In this approach, insurance becomes part of the transaction strategy rather than a separate exercise in risk management.

“Tax insurance is not an off-the-shelf insurance product. Tax insurance is a bespoke, strategic tool designed to create certainty around a supportable tax position,” says Justin Berutich, Executive Director, Head of Tax.

That philosophy has underpinned Euclid’s evolution from a small specialist tax practice into a platform built on specialist depth. The goal has remained giving clients access to professionals with experience across a broad range of tax issues, industries and major jurisdictions, while creating a clearer decision-making environment around a supportable tax position.

Expertise Built for Complex Tax Risk

Tax positions rarely fit neatly within a single jurisdiction or category. A complex matter may involve advisors in different countries, several tax authorities and competing interpretations. Accordingly, tax insurance requires professionals who understand tax law, insurance structures and commercial objectives and can approach each matter on its own terms. Euclid brings those perspectives together around a single risk, so that complex matters receive both technical tax analysis and disciplined insurance judgment.

Over the past year, Euclid’s global tax team grew from 21 professionals to more than 25 tax specialists across North America, EMEA and APAC. The continued growth and breadth of experience supports evaluation of a broad range of tax issues across industries and major jurisdictions, while its globally connected platform allows the professionals most relevant to a matter to collaborate in real time. The team has also surpassed USD 22 billion in cumulative policy limits placed since inception, evidence of the scale and maturity of that underwriting experience.

That global depth informs an underwriting model built around the client’s business decision. Once Euclid understands the objective, it evaluates the technical and commercial considerations surrounding the opportunity and tailors the insurance structure accordingly. Because the team approaches each matter with a commercial mindset, the process is tailored to the specific opportunity rather than driven by a formulaic, standardized model.

The bespoke nature of the approach comes from tailoring the solution to the circumstances of each matter. A position arising from an acquisition may require a different structure from one connected to a restructuring, tax credit or strategic planning initiative. Limit, retention, duration and policy wording are calibrated to the specific exposure rather than applied from a standard form.

“One of the advantages of our connected platform is that we can draw upon professionals with specialized experience relevant to the specific issue being evaluated,” adds Wai Ling Low, SVP, APAC Tax.

Clients’ recurring feedback centers on responsiveness, expertise, collaboration and commerciality. The feedback reinforces the commercial mindset behind the underwriting model: Euclid is designed to understand the matter quickly, coordinate the appropriate perspectives, and develop solutions rather than simply highlight problems.

Tax Insurance as a Strategic Tool

Tax insurance is still often associated with M&A, which remains an important part of the market. However, Euclid’s broader view starts from a different premise, recognizing that tax uncertainty can arise whenever a business decision intersects with tax law. The company applies its approach to strategic tax planning, corporate restructurings, renewable energy tax credits, transfer pricing and cross-border matters.

Critically, those situations do not require a buyer, seller or transaction deadline. Tax insurance can therefore serve as a planning tool, not only as transaction protection. Greater awareness has helped tax insurance become a risk-management tool inside and outside M&A, and Euclid sees this broader application as an important opportunity for the continued evolution of the market.

A Partnership That Continues After Underwriting

When an insured tax position is challenged, Euclid’s philosophy is one of alignment. The company insured the position because it and the policyholder believed it was proper and well-supported.

“Our interests and the insured’s are fully aligned. We insure tax positions because we believe in them, and we stand behind those positions with conviction,” says Berutich. Claims are, therefore, not adversarial. Underwriting and claims sit within the same organization and remain in close communication. Claims professionals bring real-world experience of how tax disputes develop and what policyholders encounter during controversies; those lessons can inform future underwriting decisions and policy wording. In turn, underwriting knowledge gives the claims team a clear understanding of the risk that was originally assessed.

That structure produces measurable results. Euclid has the industry’s largest claims team with 30 full time claims professionals, and the team has facilitated the payment of more than USD 1.8 billion across its transactional liability book.

For the policyholder, that alignment means continuity when a tax authority raises a question. Euclid coordinates with the insured, advisors and broker partners as matters move through audit, appeals, litigation or settlement discussions, helping navigate what can otherwise be a stressful and time-consuming process.

Creating Certainty Where It Matters Most

In one recent cross-border restructuring, a client faced approximately USD 50 million in potential tax exposure if tax authorities disagreed with the intended tax treatment. Although the position was well-supported, the complexity of the matter required coordination among advisors located in multiple jurisdictions and consideration of differing tax authority perspectives.

Euclid evaluated the opportunity, brought together the relevant perspectives and structured an appropriate policy. The insurance transferred a potentially significant financial consequence to the insurance market, providing the client greater confidence to focus on its commercial objectives while retaining the flexibility to pursue the intended restructuring.

Euclid bound more than 60 tax policies in the second quarter of 2026 alone. Alongside record submission activity and record policy production across multiple consecutive periods, the figure reflects the frequency with which the team is applying its approach to complex tax matters and the growing adoption of tax insurance.

Tax authorities’ enforcement, information sharing and scrutiny continue to intersect with evolving international tax regimes, tax credits, transfer pricing and cross-border structures. As tax risk becomes more global, businesses face uncertainty precisely when a supportable tax position may be important to a strategic decision. That is creating a wider role for tax insurance in restructurings, tax credit transactions, strategic tax planning and other situations where certainty can create meaningful commercial value.

As tax insurance expands beyond M&A, Euclid helps clients use it not only to transfer risk, but to make complex decisions with greater confidence. Its integrated claims model extends that support beyond underwriting, giving clients continuity when a tax position is challenged.

That approach reflects a broader objective: building a team capable of bringing together the technical expertise, global collaboration and commercial judgment needed to evaluate increasingly complex tax matters across industries and jurisdictions. The growth of its specialist bench, the more than USD 22 billion in cumulative policy limits placed, and the expanding use of tax insurance beyond traditional M&A transactions reflect the continued maturation of both Euclid’s practice and the broader market.

By combining specialist depth with a globally connected and collaborative approach, Euclid is positioned to help clients navigate the increasingly interconnected nature of tax risk—from the initial commercial decision through the life of the policy. It is also the context for this year’s recognition: Euclid Transactional has been named Tax Liability Insurance Company of the Year for 2026 by Insurance Business Review, having received the same distinction for 2025. Consecutive recognition reflects not a single strong year but the consistency of the platform, the people and the claims commitment behind it.