Practice Areas
Michael advises corporate and private clients on contentious and non-contentious matters across a range of revenue law areas, including direct and indirect tax.
Michael now has more than 15 years of experience in litigating significant and high-value tax disputes in the UK both for and against HMRC.
Recent notable areas of litigation include:
– The interpretation of double tax treaties
– The tax treatment of distributions
– Motive tests, where tax is alleged to have been a main purpose of a transaction.
– Computation of business profits, including disputed accounting matters.
– VAT exemptions for financial services
– VAT grouping
– SDLT reliefs and the distinction between residential and non-residential property
In addition, Michael advises on a broad spectrum of matters.
For example, in relation to corporates, he has advised on loan relationships, the intangible assets regime, capital allowances and international tax issues such as diverted profits tax and double tax relief.
And in relation to private individuals, Michael is familiar with many of the issues facing high-net worth individuals including the remittance basis, reliefs from CGT, IHT and income tax/NICs on employment income (including disguised remuneration).
Recent Notable Cases
• Mudan & Anor v Revenue And Customs [2025] EWCA Civ 799
• Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs [2025] UKSC 2
• Target Group Ltd v Revenue and Customs [2023] UKSC 35
• Revenue and Customs v SSE Generation Ltd [2023] UKSC 17
