Tax litigation experience

  • Tax fraud - advising senior executives of a substantial UK building society in relation to an investigation into tax fraud by HMRC.
  • Negligent tax advice - advised a PLC on claims against a firm of tax advisors for approximately US$100 million  arising out of multi-jurisdictional tax advice.
  • Big Four accountancy practice - regularly act for this accountancy practice in relation to advising on and defending claims of allegedly negligent tax advice.
  • Raid by HMRC - advised and attended a raid by HMRC on the premises of an accountant.
  • Indofood International - advised the claimants up to the Court of Appeal and winning in Indofood International Finance Ltd v JP Morgan Chase Bank NA London Branch [2006] STC 1195.
  • Capital allowance dispute - advised an infrastructure company in a capital allowance dispute against HMRC and acting for the company at Special Commissioners.
  • Investment trust - advised a listed investment trust on liabilities and claims in connection with tax exposures arising from the use of structured treasury products and risks to its investment trust status.
  • Cases on appeal - advising in cases on appeal to the Special Commissioner, High Court, Court of Appeal and House of Lords.
  • Disputes with HMRC - advised on a number of high-value disputes with HMRC involving leasing structures and the ability of our clients to claim capital allowances.
  • Group payment arrangement - negotiated the final resolution to a dispute with HMRC in relation to a Group Payment Arrangement involving a major insurance group and its broking arm.
  • Transfer pricing assessments - defended against transfer-pricing assessments in the oil and gas, shipping and real estate sectors.
  • Tribunal representation - appeared in VAT tribunals on behalf of clients.
  • Tax indemnities - advised a number of lessees on their potential liability under tax indemnities to the finance lessor.
  • Private bank - advised on its customers’ potential claims arising from the failure of a tax avoidance scheme created by a global financial institution.
  • Real estate investment company - advised on liabilities and claims in connection with a capital loss scheme.
  • Tax investigation - advised senior management of a well-known financial institution in a criminal and civil investigation being conducted by HMRC, including PACE interviews under caution.

Enthusiastic and always ready to

Chambers UK 2010