Ashley Greenbank Partner

Partner
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Ashley advises on the full range of corporate tax issues, but particular specialisations include the corporate tax aspects of UK and cross-border corporate finance and M&A transactions, group tax planning and dispute resolution.

Ashley also advises companies on group structuring and strategic tax planning (including corporate residence, permanent establishment, transfer pricing and CFC issues) and assists our private client group on corporate tax aspects of structuring issues for substantial privately held groups.

Ashley also has broad experience in handling disputes with tax authorities. He is a Deputy High Court Judge, a Deputy Judge in the Upper Tribunal (Tax and Chancery) and a CEDR accredited mediator.

Ashley is a former chair of the Tax Law Committee of the Law Society and a member of its Corporation Tax Sub-Committee. In that capacity he is active in making representations to and in consultations with Government and tax authorities on changes to existing legislation and new policy proposals. He is also a member of the committee of the British Branch of the International Fiscal Association and the organising committee for the IFA Congress in London in 2019.

Expertise

Recent work

Jazz Pharmaceuticals plc

Advising Jazz Pharmaceuticals plc, a biopharmaceutical company based in Ireland, on its acquisition of GW Pharmaceuticals plc for a total consideration of $7.2bn, announced in February 2021.

Quayle Munro

Designing a structure for Quayle Munro involving a three-way break-up of their group, implemented under two court-sanctioned schemes of arrangement in separate Scottish companies. Implementation was co-ordinated by Macfarlanes’ corporate team. This was the first time that the Scottish courts had considered and sanctioned the use of inter-conditional court schemes of arrangement.

Blackstone

Providing UK tax and structuring advice to investment funds managed by Blackstone, the majority shareholders in Refinitiv, on the merger of the London Stock Exchange and Refinitiv, which will result in the Refinitiv shareholders acquiring a 37% stake in the London Stock Exchange in an all share transaction with a total enterprise value of approximately $27.2bn.

Virgin

Advising Virgin on the demerger of the loyalty programme business of Virgin Atlantic to its shareholders (Virgin and Delta) and the development of a wider Virgin-branded loyalty business which is to be launched across the Virgin group. We designed a structure which ensured tax neutral treatment for all of the participants, including the UK and US shareholders.

Visa Inc.

Advising Visa Inc. on its acquisition of Visa Europe for a total value of €21.2bn.

Verizon Communications Inc.

Advising Verizon Communications Inc. on its acquisition of Vodafone’s interest in Verizon Wireless for $130bn.

The Virgin Group

Advising the Virgin Group on the joint venture arrangements with Delta Airlines in relation to Virgin Atlantic

See all

What people are saying

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"He is brilliant technically, very responsive and fun to work with."

Chambers UK 2022

"He knows his stuff extremely well and is really straightforward."

Chambers UK 2022

"He is a guru who is able to digest complex tax legislation and give us answers we can understand."

Chambers UK 2021

"He is very creative, measured and communicates very well."

Chambers UK 2021

"He's smart, thoughtful, creative and always a great pleasure to work with."

Chambers UK 2020

"The "excellent" Ashley Greenbank is accomplished in handling reorganisation and restructuring processes along with a wide range of M&A-related tax matters."

Chambers UK 2019

Quick reads

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In depth

Unpacking Pillar Two: issues and planning for investment portfolios

Ashley Greenbank, Lucy Urwin 19 Jul 2022
The treatment of investment portfolios under the GloBE rules is likely to prove particularly complex. This will be the case whether the portfolio in question is held as part of a...
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Unpacking Pillar Two: trust issues

Ashley Greenbank, Lucy Urwin 15 Jul 2022
The application of the new global minimum tax will create added complexity for groups whose holding structure includes non-corporate entities such as trusts.
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Unpacking Pillar Two: transition rules

Rhiannon Kinghall Were, Ashley Greenbank 13 Jul 2022
When a group becomes subject to the GloBE rules for the first-time special rules are required to manage pre-existing losses or other timing differences in order to prevent...
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