Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Gideon advises corporates and individuals on complex tax investigations and litigation. His tax litigation work has given him experience at all levels of the UK Courts and the European Courts.
Gideon has worked on disputes and investigations involving complex corporate and financial transactions for a variety of multinational and FTSE listed companies across both direct and indirect tax, as well as dealing with investigations involving high-net-worth individuals.
Gideon also has significant experience in addressing matters relating to economic crime, raising public law challenges and addressing high value professional negligence.
Gideon takes a particular interest not just in advising on investigations and disputes but in seeking solutions outside of the Courts, whether through well-run compliance or effective settlements.
With a transactional background covering, in particular, M&A and finance, as well as matters with a significant international dimension, Gideon combines considerable insight into how tax investigations are pursued, with experience of how some of the most complex tax rules apply in practice.
Clients value Gideon's experience and his ability to navigate complex issues in order to achieve the best result.
Experience
- Advising a FTSE 100 company in relation to a group litigation order involving approximately 300 claimants with respect to the VAT treatment of certain supplies and their compliance with EU law.
- Advising a high profile multinational company in relation to a long-running and complex transfer pricing investigation.
- Advising a number of investment management firms on a number of claims being brought by HMRC in relation to the taxation of management fees, the application of the salaried member rules and the taxation of remuneration arrangements.
- Successfully defending an individual against a claim by HMRC that he was resident for tax purposes in the UK.
- Bringing a judicial review challenge and appeal to the Tax Tribunal with respect to HMRC’s approach to the taxation of certain Enterprise Zone arrangements.
- Acting for advisors in respect of professional claims by multiple investors concerning various film financing arrangements.
- Acting for a senior executive in relation to proceedings in which HMRC asserted fraud.
- Acting for financial institutions in relation to complex, cross-border transactions that were the subject of regulatory investigations.