Transfer Pricing and Cross-Border

  • Representing a global footwear business on its response to an enquiry into its transfer pricing adjustments, and application of the Offshore Receipts for Intangible Property regime under FA 2019.
  • Representing a large multinational business on its historic transfer pricing arrangements and obligations under the Diverted Profits Tax, FA 2015 regime, including an allegation that the directors of the company filed deliberately inaccurate returns following the publication of the BEPS 8-10 Actions.
  • Representing a multinational, regulated professional services partnership on its failure to register for a number of years a UK permanent establishment.

Corporate Tax

  • Representing a global high-tech manufacturing business on its response to an enquiry into its treatment of certain non-standard receivables in connection its multi-$billion flagship design and build project as capital not revenue for the purpose of Part 3, CTA 2009.
  • Representing various corporates denied relief for interest payments under the unallowable purpose test under the Loan Relationship Rules in Part 5, CTA 2009.
  • Representing a major retail group on the application of the Transfer of Income Stream legislation Part 16, CTA 2010, degrouping charges and anti-avoidance tests in s.931O and s.931N, Part 9A CTA 2009.

Withholding taxes

  • Representing BT Pensions Scheme and others in litigation seeking payment of tax credits on dividends related to overseas investments (Manninen/FIDs).
  • Representing Coal Super Annuation Scheme and others in litigation seeking recovery of Manufactured Overseas Dividend withholding tax.

Criminal

  • Representing the first corporate placed under criminal investigation by HMRC under section 43, Criminal Finances Act 2017.
  • Advising a range of clients, including a global bank, on risks assessments and reasonable prevention procedures in response to the Criminal Finances Act 2017.
  • Representing a ultra-high net worth individual facing criminal investigation into alleged fraud on post-exit and pre-entry planning surrounding her move from the US to the UK, securing her release without charge.