Rupert is an official CPDcast contributor and contributes to the following podcasts:
Rupert advises individuals and corporations on resolving disputes with HMRC. He has particular expertise in corporation tax (and other business tax) disputes, EU law claims, and anti-avoidance issues.
Rupert focuses on the technical and tactical management of difficult Revenue enquiries, negotiating with HMRC to concede issues or agree settlements. He also has extensive experience in the preparation and conduct of cases in the Special Commissioners, the English High Court, and the European Court of Justice.
Rupert often deals with matters with significant technical tax content. He lectures and writes extensively, particularly on EU law and anti-avoidance principles.
Rupert's recent projects have included:
Negotiating with HMRC Special Civil Investigations Office in relation to pre-packaged tax planning arrangements providing some £70million of capital losses to a large group of individuals.
Advising a FTSE-250 company on extremely complex and high value Special Commissioners' proceedings (relating to the life assurance tax regime), concluding a settlement shortly before the hearing with HMRC entirely abandoning their claim to tax.
Advising a globally-recognised brand name in the automotive sector on a reference to the ECJ in Class 4 of the ACT Group Litigation, challenging the EU-compliance of the UK's regime of treaty credits on cross-border dividends.
Advising a FTSE-100 company on the application of UK anti-avoidance rules to $1.5bn current and intended cross-border financing arrangements.
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