Experience

An ultra-high-net-worth individual

Suing HMRC for breach of contract in connection with the issue of assessments for over £1bn of tax and interest

A French marine services company

Handling a dispute and negotiations with the French tax authorities concerning an alleged permanent establishment issue

A multinational tech company

Advising a major multinational technology company in relation to a multi-year tax audit conducted by the ATO, focusing on transfer pricing, withholding tax and tax treaty issues, as well as offshore information requests and appearances before the Senate’s Tax Inquiry

BHP

Advising in Supreme Court of Queensland proceedings on its $300 million+ dispute with the Queensland Treasurer on coal royalties

Commonwealth Bank of Australia

Advising the banking group on its R&D Incentive dispute with Innovation & Science Australia and the ATO in proceedings in the AAT

Investment partnerships

Challenging successfully in the Court of Appeal the settled view of HMRC as to the tax status of commercial mortgage backed securities

Tax UK Notes

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