Rupert is a partner in the tax disputes and investigations team and is based in our London office. He leads the "large corporate" practice for direct tax disputes.
Expertise
Rupert advises corporates, individuals and other taxpayers on resolving disputes with HMRC.
He has over ten years' tax experience. He manages and drives forward appeals to the tax tribunal, and other court proceedings against HMRC. He is also frequently involved in breaking deadlock in long-running enquiries and achieving settlements.
Rupert is rated as a market-leading advisor in resolving tax disputes. Chambers and Partners rates him as a Band 1 individual for "Best of the UK" in Contentious Tax. He is also recommended in Legal 500, which describes him as "creative and energetic" (2009) and "technically excellent" (2008). Chambers says that he is "seriously smart and dedicated" (2010) and "driven, keen, and leaves no stone unturned" (2009).
In addition to his experience in resolving disputes with HMRC, Rupert has four years' experience as a corporate tax advisor in a major international practice, focusing particularly on M&A transactions, reorganisations, and innovative corporate and investment structures. He also studied tax law at post-graduate level at the University of Oxford.
Rupert is a member of the Chartered Institute of Taxation "Management of Taxes" sub-committee. He speaks regularly at commercial, academic and HMRC seminars on tax and tax disputes issues. His comment and analysis is regularly published in the tax and financial press. He is a recognised authority on Transfer Pricing disputes and is a lead contributor to the LexisNexis global on-line service on the subject.
Recent projects include:
- Corporation tax - advising the Legal & General group in successful Tribunal proceedings dealing with the interaction of the FSA regulatory regime and UK corporation tax rules (Legal & General Assurance Society Limited v HMRC [2009]). Advising a major UK plc aiming to break deadlock in a long-running enquiry dealing with the capital or revenue character of ordinary business transactions
- Transfer pricing - breaking deadlock in a long-running enquiry for the UK sales and servicing subsidiary of a Japanese manufacturer. Advising a major investment fund on the risk of material challenge by HMRC to their global transfer-pricing policy
- Anti-avoidance - conducting negotiations relating to CGT planning with HMRC Special Civil Investigations on behalf of a group of individuals, and achieving settlement. Advising an individual in successful HMRC negotiations in 2009 on settlements relating to bespoke offshore tax planning. Advising the taxpayers in the leading cases Astall v HMRC [2009] (Court of Appeal) and Drummond v HMRC [2009] (on appeal to the Supreme Court)
- EU issues - advising the Philips group in their ground-breaking Tribunal success in challenging the UK consortium relief regime (Philips Electronics UK Limited v HMRC [2009]). Advising a FTSE-100 group in high-profile tax tribunal proceedings challenging the UK's CFC regime. Advising a major UK retailer on a successful reclaim of SDRT under EU principles. Acting for participants in the various High Court group litigation orders, challenging aspects of the UK's corporation tax regime
- Judicial review - advising a group owned by venture capital funds on judicial review, challenging HMRC's refusal to honour commitments said to be made during the 1998 consultation process for the current transfer-pricing regime
Approachability
On important matters you'll spend a lot of time with your lawyers. So as well as working to get you the result you want, we also try to make it enjoyable.