Tax

Michael’s main area of practice is in tax, particularly the intersection of tax and public and administrative law. He represents taxpayers and HMRC alike. He has experience in the First Tier (Tax) Tribunal, the Administrative Court, and the Court of Appeal.

Michael has particular expertise in tax and employment status cases, as well as the new IR35 rules for the public sector. He was instructed to provide a second opinion to the Locum Doctors Union in relation to NHS Improvement’s implementation of the new IR35 rules, and subsequently was instructed in the LDU’s judicial review challenge to NHS Improvement’s purported implementation of IR35.

Michael has specific experience of public international law within the tax sphere, including questions of bilateral tax treaty interpretation, sovereignty, jurisdiction, and enforcement. Michael has in the past worked with a magic circle law firm in a multi-billion GBP international tax case involving tax treaty construction and conflict of constitutional law issues.

Michael accepts both direct access and licensed access instructions.

Selected Cases

  • Successful in submissions on behalf of an international corporate in relation to an application by HMRC pursuant to paragraph 3 Schedule 36 the Finance Act 2008.
  •  Successful in a judicial review challenge (via the pre-action protocol) brought by an established trading company to two separate accelerated payment notices (“APNs”) issued by HMRC’s counter avoidance unit. More details available here.
  • Acting in Code of Practice 9 cases involving businesses and entrepreneurs across a diverse range of sectors including technology, software, telecoms, wealth management and accounting.
  • Acting in alternative tax dispute resolution cases involving HMRC’s disguised remuneration settlement opportunity.
  • A successful judicial review challenge (via the pre-action protocol) brought by the Locum Doctors Union to NHS Improvement’s purported implementation of the new IR35 rules for the public sector. Michael was instructed by Duncan Lewis and the case reported as a leading story in both the Times and the Telegraph.
  • A successful judicial review challenge (via the pre-action protocol) brought by an established trading company to two separate accelerated payment notices (“APNs”) issued by HMRC’s counter avoidance unit. Following service of the taxpayer’s judicial review pre-action protocol letter, HMRC decided to withdraw both APNs. Following further representations HMRC agreed to rescind the underlying tax assessment, thereby obviating the taxpayer’s purported liabilities in their entirety.
  • A successful defence of a leading regional accounting business in an HMRC inquiry into whether the firm was meeting its PAYE obligations under the Construction Industry Scheme.
  • Advised a national construction company on the flat-rate scheme for small businesses under the Value Added Tax (Amendment) Regulations 2017 in the context of the commercial arrangements for a proposed multi-million GBP trading enterprise (with Roderick Cordara QC).
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