UK

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 (0) 207 007 3079; +44 (0) 121 695 5011

Mobile: +44 (0) 7775 807510

Email: saustin@deloitte.co.uk

Website: www.deloitte.com

Shaun has more than 12 years of experience as a partner, and 20 years of experience in transfer pricing.

He has been the partner responsible for the UK regional transfer pricing practice from 2007, and has been the partner in charge of the UK national transfer pricing practice from 2009. Shaun is now European transfer pricing leader.

Shaun has extensive experience in advising a broad range of clients in all areas of transfer pricing including planning, documentation, audit defence and MAP, and debt pricing.

Shaun was listed in the most recent version of Euromoney's Guide to the World's Leading Transfer Pricing Advisers. He studied at Cambridge University and is a member of the Institute of Chartered Accountants in England & Wales (ICAEW).

3 Field Court

Gray’s Inn

London WC1R 5EP

Tel: +44 (0)20 3693 3700

Website: www.fieldtax.com

Philip Baker is a barrister and Queen's Counsel practising from Field Court Tax Chambers in Gray’s Inn. He was called to the bar in 1979, began practising in 1987 and took silk in 2002. He became a bencher of Gray’s Inn in 2011. He was previously a member of Gray’s Inn Tax Chambers until July 2014. He specialises in international tax issues, with a particular emphasis on double tax conventions, and on European Union law and taxation. He has a particular interest in the European Convention on Human Rights and taxation.

Before moving into practice, Philip taught law for seven years at the School of Oriental and African Studies, London University. He was subsequently a visiting professorial fellow at Queen Mary University of London, and is now a senior associate fellow of the Institute of Advanced Legal Studies, London University. He is the author of Double Taxation Conventions and International Tax Law and the editor of the International Tax Law Reports.

In recent years, Philip has been involved in litigation in the UK tax tribunals and the Court of Justice of the European Union concerning consortium relief for losses under non-discrimination provisions and EU law (Felixstowe Docks), and in the High Court and Court of Appeal on the cross-border enforcement of taxes (Ben Nevis). He has also acted as an expert witness in India (Vodafone) in the US (Entergy, PPL, Bank of New York) in Norway (Transocean) and other countries; he has also been involved with several arbitrations on tax-related issues. He appears on behalf of the Mauritius government in Privy Council appeals.

Philip’s advisory practice covers UK and international tax law, and extends to both private client matters (largely cross-border issues) and corporate matters, including multinational group tax issues.

Philip is a member of the Permanent Scientific Committee of the International Fiscal Association, the Exchequer Secretary’s Tax Professional Forum, and the International and EU committees of the Chartered Institute of Taxation and of the Law Society.

1 Embankment Place

London WC2N 6RH

UK

Direct: +44 (0)20 7212 3142

Mobile: +44 (0)7710 737703

Email: stephen.camm@uk.pwc.com

Website: pwc.com/taxcontroversy

Alternative contact:

Whitney Foot

Direct: +44 (0)20 7212 5069

Email: whitney.foot@uk.pwc.com

Stephen Camm is a partner at PwC in the UK and leads the firm's tax disclosure and tax transparency team. He is acknowledged as one of the UK's leading experts on information exchange developments and the handling of tax disclosure cases.

For many years Stephen has helped people and businesses, large and small, manage their relationship with HM Revenue & Customs (HMRC). He spent 15 years at HMRC, including spells in the Special Compliance Office and the Large Business Office, before joining PwC.

An expert in negotiation and direct tax enquiry matters with a first class record of helping clients, Stephen has been listed as one of the UK's leading tax controversy experts by International Tax Review several times.

Abbots House

Abbey Street

Reading, RG1 3BD

UK

Tel: +44 (0) 118 322 2376

Email: rcoombes@deloitte.co.uk

Website: www.deloitte.com

Richard has been a tax specialist since 1985 and has specialised in transfer pricing since 1992. He spent 16 years with HMRC, the UK tax authority, as a corporate tax and transfer pricing specialist, including seven years as a transfer pricing specialist in HMRC's London head office. While in head office he undertook a range of operational and policy roles, including working on some of the UK's largest transfer pricing investigations, acting as lead inspector in several rounds of high profile litigation, delivering national programmes of training in transfer pricing, PE and business model reorganisations, acting as Competent Authority, and advising the UK government on legislative and procedural reform.

Richard has worked in Deloitte UK's transfer pricing practice for 12 years. He is experienced in business model and transaction flow design, and specialises in planning, design and defence of transfer pricing structures, with a particular emphasis on intellectual property and intangibles. He also uses his tax authority experience to help lead Deloitte UK's tax authority transfer pricing work – being advance pricing agreements (APAs) and dispute resolution (including enquiry defence and competent authority work). In the past three or four years Richard has advised on mutual agreement procedures (MAPs) and APAs between the UK and more than a dozen of its treaty partners, including the first ever UK-Poland APA. Richard also remains active in devising and delivering training and in public speaking and technical writing.

Richard has an MA from Cambridge University and is studying Russian.

Hays Galleria

1 Hays Lane

London SE1 2RD

UK

Tel: +44 (0)20 7804 5260

Fax: +44 (0) 20 7804 2299

Email: peter.cussons@uk.pwc.com

Website: pwc.com/taxcontroversy

Peter Cussons ACA, ATII, MA (Cantab) Hons is an international corporate tax partner at PwC. Peter qualified as a chartered accountant in 1978, and qualified as associate of the Chartered Institute of Taxation (CIOT) in 1979.He became a partner in Price Waterhouse in 1987.

Peter leads PwC's EU direct tax group, which covers EU law related tax developments. He is also a client tax partner, with a wide range of UK and internationally-based corporate clients.

Peter's previous relevant experience includes acting as instructing accountant in the ACT Class 2 & 3 Group Litigation Orders (High Court and Court of Appeal) and in the depreciation in stock case (Special Commissioners, High Court and House of Lords). He has also acted as instructing accountant in the Marks and Spencer PLC v Halsey case (High Court, Court of Appeal, ECJ, First Tier Tribunal and Upper Tier Tribunal).

Peter chairs the Large Business and International Committee of the ICAEW's tax faculty, and is also a member of the faculty's technical committee. Peter is also a member of the international tax committee of the CIOT.

Peter is the only Big 4 partner on the Confederation of British Industry's main tax committee.

He is a frequent contributor to various tax publications and is cited in the Financial Times and other papers/journals regularly. Peter is also on the editorial board of the Tax Journal and is a guest lecturer at Queen Mary, University of London.

Peter Cussons has also been instrumental in various direct tax infringement proceedings by the European Commission and has led or assisted some high profile group litigation orders (GLOs) in the UK, including the recently granted Stamp Taxes GLO.

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 8935

Email: jonathan.elman@cliffordchance.com

Website: www.cliffordchance.com

Jonathan Elman specialises in taxation of corporate and financing transactions and has a high level of court and tribunal experience. He is regularly ranked in the top band of tax lawyers in the UK and is consistently seen as a leading individual.

Jonathan's recent dispute experience includes a significant victory for the taxpayer in the ongoing case of Fidex Limited v HMRC [2013] UKFTT 212 (TC), which has been widely commented on in the legal press. This was an important win at the (UK) First Tier Tribunal and the first time a taxpayer has prevailed in a dispute over the paragraph 13 anti-avoidance rule.

Jonathan is an integral member of Clifford Chance's tax disputes practice, arguably the most experienced group of partners who deal with contentious tax matters.

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 2044

Email: liesl.fichardt@cliffordchance.com

Website: www.cliffordchance.com

Liesl Fichardt leads Clifford Chance's contentious tax practice and is one of the UK's leading tax disputes practitioners. She has extensive experience in tax litigation, negotiations with revenue authorities and settlement of disputes. She possesses considerable court and tribunal experience including conducting cases in the Tax Tribunal, the courts of appeal and the Court of Justice of the European Union (ECJ). Liesl practised as a tax barrister for 13 years and previously acted as a judge in the High Court of South Africa. She is deputy chairwoman of the British branch of the International Fiscal Association.

Liesl is top rated in leading legal directories including being listed in International Tax Review's Tax Controversy Leaders Guide for her outstanding success and for consistent positive feedback from clients and peers.

Liesl leads arguably the most experienced group of partners who deal with tax investigations, litigation and dispute resolution. The combination of local expertise and global connectedness allows Clifford Chance to handle complex disputes effectively and efficiently, whether in the UK or any other jurisdiction.

Clifford Chance advises multinationals, financial institutions, corporates and high net worth individuals on tax and VAT matters covering the entire range of tax dispute resolution including:

• Prevention related advice, risk assessments and risk management;

• Tax audits and tax raids;

• Tax compliance related advice;

• Investigations (both civil and criminal);

• Negotiation and drafting of settlements with tax authorities;

• Cross-border disclosure requests from tax authorities;

• Tax litigation before national and international courts, specialist tax tribunals, the courts of appeal and the ECJ;

• Parliamentary, European Commission and similar investigations;

• Lobbying revenue authorities on the formulation of tax legislation and guidelines; and

• Enforcement proceedings.

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 8949

Email: david.harkness@cliffordchance.com

Website: www.cliffordchance.com

David Harkness specialises in corporate and international tax planning and has particular experience in advising banks and financial institutions on public takeover issues and tax disputes. David is regularly ranked in the top band of tax lawyers in the UK and is consistently seen as a leading individual.

David's recent contentious tax experience includes advising on the corporate tax aspects of a number of cases involved in group litigation orders (GLOs) including cross-border group relief claims, cross-border dividend claims and SDLT claims, in some instances working with the major accounting firms.

David is an integral member of Clifford Chance's tax disputes practice, arguably the most experienced group of partners who deal with contentious tax matters.

15 Canada Square, Canary Wharf

London E14 5GL

UK

Tel: +44 20 73113053

Email: paul.harrison@kpmg.co.uk

Website: www.kpmg.com/uk

Paul Harrison joined KPMG in the UK in 1995 after nine years as a senior tax inspector with HM Revenue & Customs (HMRC), where he occupied senior positions and handled the largest cases of suspected fraud and avoidance.

Paul leads a national UK team of professionals dedicated to helping clients deal with contentious tax matters of all kinds. Paul personally leads the largest and most complex contentious tax controversy projects and has advised a diverse range of clients from multinational corporations to high net worth individuals. Paul is recognised by his peers and by HMRC as a leading tax professional and has forged strong professional relationships with many senior HMRC officials.

1 Embankment Place

London WC2N 6RH

UK

Tel: +44 (0)20 7212 5157

Email: diane.hay@uk.pwc.com

Website: pwc.com/taxcontroversy

From 2004 to 2008 Diane was the deputy director at HM Revenue & Customs with responsibility for a wide range of international corporate tax issues, including transfer pricing, controlled foreign companies (CFCs), company residence and double tax relief. She led the reorganisation of transfer pricing administration in the UK and was the first chairperson of HMRC's Transfer Pricing Board. Diane led the team that litigated the UK's only substantive transfer pricing case, DSG Retail Ltd and others v HMRC (2009), as well as preparing three other major cases for potential litigation.

As the UK's Competent Authority, she had responsibility for the Mutual Agreement and the Advance Pricing Agreement programmes. She also served on OECD's Working Party 6 Bureau on Multinational Enterprises and was the HMRC representative on the OECD Committee on Fiscal Affairs.

After leaving government, Diane joined PwC in London as a special adviser on international corporate tax and became one of the first members of PwC's global tax controversy and dispute resolution network. Her areas of expertise are APAs, dispute resolution and building relationships with HMRC. Diane is advising on several APAs with some of the world's largest businesses, and specialises in developing multiple APA strategies. In the areas of dispute resolution, Diane advises on both domestic and international cases where she can leverage her excellent relationships with HMRC and other tax authorities.

More recently, she has been working with an increasing number of clients who are looking to move their headquarters or centralise their businesses in the UK by helping them to obtain certainty on their future tax treatment across a wide range of issues. Diane has maintained her many relationships at senior levels in both HMRC and HM Treasury.

Diane is on the UK branch committee of the International Fiscal Association and was the UK rapporteur for the 2013 IFA Congress covering exchange of information. She is on the editorial board of International Taxation and co-edited the first and second editions of 'Taxation of Foreign Profits'. She is a frequent speaker at conferences and writes several articles each year.

Four Brindleyplace

Birmingham, B1 2HZ

UK

Tel: +44 121 695 5722

Email: ojarratt@deloitte.co.uk

Website: www.deloitte.com

Oliver Jarratt is a director with Deloitte UK. His role is to lead Deloitte's dispute resolution group for indirect tax in the Midlands and North in the United Kingdom.

Oliver and his team help to resolve clients' disputes with HMRC by the most appropriate and cost-effective means (such as negotiation, alternative dispute resolution or Tribunal litigation), and they are involved in a wide range of consultancy work with complex technical angles. The vast majority of Oliver's work relates to value added tax (VAT), but he also advises on customs duty and some environmental taxes, assisting clients of all sizes, from multinational to local. Oliver works across all industries, but with particular emphasis on the consumer business and automotive sectors.

Athene Place

66 Shoe Lane

London, EC4A 3BQ

UK

Tel: +44 20 7007 0688

Email: akhan@deloitte.co.uk

Website: www.deloitte.com

Anbreen Khan is the head of the dispute resolution group in the UK, specialising in indirect taxes. She is a partner with the Deloitte UK firm, based in London with expertise and significant experience in dealing with Indirect taxes and in particular dispute resolution work. Anbreen advises a wide spectrum of clients and has advised in a number of landmark VAT cases in the UK and at the Court of Justice of the European Union (including recently The Rank Group plc; Everything Everywhere (formerly T-Mobile)). Other notable cases include: Marks & Spencer Plc; Association of Investment Trust Companies/JP Morgan Fleming. These cases have made an outstanding contribution to UK business and the development of tax policy.

Anbreen has extensive experience in dealing with complex VAT legal issues and negotiations in relation to collaborative tax dispute resolution. Anbreen leads a group of tax specialists in the UK who provide a dedicated dispute resolution service across both indirect tax and corporate tax. The team has a high market profile winning awards for Best UK VAT Team in 2007 and 2009 as well as being voted the best Big 4 tax team in 2011.

Anbreen is a qualified lawyer; she is a former winner of the 'Rising Star' award for the Tax Journal indirect tax awards and is also a member of the Institute of Chartered Accountants England and Wales. Anbreen was recently listed as an indirect tax expert in both the 2012 and 2013 editions of the Indirect Tax Leaders guide.

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 20 7007 0871

Email: jamarsh@deloitte.co.uk

Website: www.deloitte.com

Jason joined Deloitte UK in 1991 and has been a partner of the Deloitte UK corporate tax practice in London since 2001. He is a qualified mediator (by the Centre for Effective Dispute Resolution – CEDR) and has been a founding member of Deloitte UK's tax risk management and resolution team since 2007.

Jason has gained extensive experience working with corporate clients, and with HM Revenue & Customs (HMRC), to resolve tax disputes through HMRC's high risk corporate programme (HRCP), managing corporate risks programme (MCRP) and collaborative dispute resolution (CDR) processes and governance frameworks.

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 207 007 6568

Mobile +44 7813 292806

Email: edmorris@deloitte.co.uk

Website: www.deloitte.com

Since joining Deloitte UK, Edward has advised on many transfer pricing issues across many industries and has been instrumental in forming Deloitte's global competent authority network of ex-government and specialised expertise to help clients with all forms of dispute resolution and dispute prevention. In particular, Edward has helped many clients negotiate successful advance pricing agreements (APAs) and mutual agreement procedures (MAP) and to resolve ongoing transfer pricing enquiries.

Edward joined Deloitte UK in 2009 after a career in the head office of HM Revenue & Customs' (HMRC) international division. He was involved in a range of international tax issues and problems but specialised in transfer pricing, PEs and treaty matters and represented the UK at the OECD.

Edward served as the UK delegated competent authority for MAP and EU arbitration cases. This work involved dispute resolution as well as dispute prevention work on APAs, with fiscal authorities around the world.

Previously, Edward led many of HMRC's transfer pricing enquiries into the biggest and most complex cases, including involvement in litigation work before the UK courts.

Edward enjoyed a two and half year secondment to Brussels, where he served on the secretariat to the EU Joint Transfer Pricing Forum (JTPF), helping to update the EU Arbitration Convention and the various associated codes of conduct. Edward's magnum opus were the EU APA guidelines adopted by all 27 member states.

Edward has also spent considerable time at the OECD, attending Working Party 6 on transfer pricing (including the sub groups on dispute resolution and business restructuring), either for the UK or as Commission observer and latterly as a private sector representative. Edward also attends meetings of the EU JTPF. Edward's eminence in the wider international tax field was recognised by the OECD when he was asked to speak at the 50th anniversary celebration of the OECD model tax convention and by IFA in 2011 when Edward participated in the opening plenary session on business restructuring. Edward has appeared consistently in Euromoney's Guide to the World's Leading Transfer Pricing Advisers since joining Deloitte.

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 8811

Email: dan.nedile@cliffordchance.com

Website: www.cliffordchance.com

Dan Neidle specialises in the UK and international tax treatment of corporate and financial transactions and has significant tax disputes experience in the banking, finance and regulatory sectors. He has particular experience in acquisition finance and structured finance transactions and also advises representative bodies and other clients on tax policy.

Dan's recent tax disputes experience includes advising on whether an EU law challenge can be made against the proposed EU financial transaction tax and advising financial institutions on EU law claims against HMRC for the refund of historic stamp duty payments.

Dan is an integral member of Clifford Chance's tax disputes practice, arguably the most experienced group of partners who deal with contentious tax matters.

1 Embankment Place

London, WC2N 6RH

UK

Office: +44 (0)20 7213 3238

Email: christopher.p.orchard@uk.pwc.com

Website: pwc.com/taxcontroversy

Chris Orchard is a partner in PwC's tax knowledge and innovation group specialising in indirect taxes (primarily VAT). Chris has been working in indirect tax for 16 years and before that had operational management experience in the leisure industry. ??Chris is the lead PwC partner in the Investment Trust Companies case. That case concerns restitution for customers who have suffered VAT that was passed on to them by suppliers and which had been imposed by domestic statutory provisions which breached EU law. Restitution and reimbursement to taxpayers of unlawfully levied taxes is one of Chris's particular interests. Chris has experience of resolution and litigation of indirect tax disputes across a wide variety of industry sectors including both private and public sectors.

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 20 7007 6580

Email: trowbotham@deloitte.co.uk

Website: www.deloitte.com

Tom Rowbotham is a tax partner with Deloitte UK and responsible for the firm's strategy in the area of tax disputes. He is also a member of the global tax controversy management executive team and leads the service line in relation to all disclosure facilities. Tom has worked for large international businesses, owner managed business, and high net worth individuals and has extensive experience in dealing with all forms of tax dispute.

Before joining Deloitte UK, Tom worked for 20 years as an inspector of taxes for HM Revenue & Customs (HMRC) – the UK Revenue authority. Tom led many significant cases where HMRC raised inquiries or requested information from clients and external referrals across all aspects of industry.

As Tom's main focus is advising clients on dealings and interactions with HMRC, his experiences from working on both the side of the inspector and the client prove invaluable in providing practical commercial strategies. Tom is advising a number of clients with regards to the current initiatives around tax transparency and exchange of information.

Some highlights of Tom's project experiences include significant and varied issues covering many industry sectors delivering client favorable outcomes, information requests from HMRC which are both sensitive and potentially commercially damaging, disclosures to HMRC in areas of uncertainty to achieve a controlled outcome reflecting appropriate commercial pressures, and requests by UK and other jurisdictions under tax information exchange agreements.

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 8632

Email: david.saleh@cliffordchance.com

Website: www.cliffordchance.com

David Saleh advises on UK and international tax structuring and related corporate and contentious tax matters. An SDLT and VAT expert, David leads the firm's UK real estate tax practice. He has particular expertise in real estate tax and indirect taxes, including restructurings, mergers and acquisitions, joint ventures and tax disputes. David advised on the largest ever SDLT case in the UK, involving major stakeholders in the real estate sector. He was also one of the industry representatives in negotiations with the Treasury on the new 15% SDLT, annual residential property tax.

David is an integral member of Clifford Chance's tax disputes practice, arguably the most experienced group of partners who deal with contentious tax matters.

201 Bishopsgate

London EC2M 3AF

UK

Tel: +44 20 3130 3811

Fax: +44 20 3130 8951

Email: psteiner@mayerbrown.com

Website: www.mayerbrown.com

Peter Steiner is an experienced tax adviser who represents clients across a broad range of transactions, including real estate transactions, company and business sales and acquisitions, corporate reorganisations, and joint ventures, as well as international finance transactions involving cross-border tax planning. Peter's practice extends to the tax implications of projects generally, including global funds, and he advises clients on numerous questions regarding value added tax (VAT).

Peter has significant experience in negotiating and litigating tax disputes, including transfer pricing inquiries. He has acted in landmark cases, such as EMI Group Electronics Limited v. Coldicott, concerning the tax treatment of termination payments to employees; and the challenge by major UK electrical retailers, rental companies, and insurance companies concerning the legality of the higher rate of insurance premium tax on domestic electrical appliance (warranty) insurance.

Following a successful career as an economist in the pharmaceuticals industry, Peter retrained as a lawyer and joined Mayer Brown International in 1986.

Regularly listed as a leading individual by the legal directories, Peter "is very practical and has a very sharp mind with a keen eye for tax planning," according to clients (Chambers UK 2012). He is "very innovative" (Legal 500 2011); a "talented operator" (Chambers UK 2011); "well regarded by clients and peers alike" (Legal 500, 2010). Peter is "always looking for the best and quickest solution to a problem". Described as a "safe pair of hands" he is especially strong on property taxation, notes Chambers UK 2010.

Hill House

1 Little New Street

London, EC4A 3TR

UK

Tel: +44 20 7007 4397

Email: fwalkinshaw@deloitte.co.uk

Website: www.deloitte.com

Fiona is a litigation specialist with more than 20 years' experience of resolving complex commercial and tax disputes. She joined Deloitte UK as a partner in September 2009 to head up the direct tax litigation offering within Deloitte's wider dispute resolution group.

She has experience of both domestic and EU tax litigation and has represented clients in the tax tribunals, the domestic courts and the European Court of Justice. She has also had considerable experience of alternative dispute resolution methods such as mediation and expert determination.

1 Embankment Place

London WC2N 6DX

UK

Tel: +44 (0)20 7804 1455

Email: mark.whitehouse@pwclegal.co.uk

Website: pwc.com/taxcontroversy

Mark heads the tax disputes team at PwC Legal. He is one of the UK's leading specialists in contentious tax, having been in practice for more than 20 years. He has particular experience in the interaction of EU law with UK tax principles, tax planning challenges and judicial reviews. He was also involved in the only substantive transfer pricing case that has been litigated in the UK to date.

A large part of his practice is working with clients and HMRC to settle tax disputes before they reach court and in this context he has been involved in a number of very high-value negotiations settling some billion pound plus disputes. Reported cases include Lansdowne v HMRC [2011] EWCA Civ 1578, DSG Retail Ltd v HMRC [2009] UKFTT 31 (TC), the Stamp Taxes GLO, R (The Minister for Economic Development of the States of Jersey) v HMRC [2012] EWHC 718 (Admin) and Vocalspruce Ltd v Revenue & Customs [2012] UKFTT 36 (TC). Mark is a CEDR accredited mediator and has experience of alternative dispute resolution.

Mark's professional memberships include the Law Society, International Fiscal Association, and EU Direct Tax Group (PwC).

Before joining PwC in 2009, Mark held various roles including at Allen & Overy where he trained and qualified in 1992. He then went on to serve at the HMRC Solicitor's Office between 1993 and 1997, before moving to KPMG (and its legal practice).

7 More London

Riverside

London SE1 2RT

UK

Tel: +44 (0) 207 804 1938

Email: simon.wilks@uk.pwc.com

Website: pwc.com/taxcontroversy

Simon Wilks is the partner leading the UK PwC tax dispute resolution network – a team of around 40 dispute resolution specialists. Simon is based in the banking and capital markets team but advises clients not only in the financial services sector but across many other industries.

Simon was a tax inspector with the Inland Revenue (now HMRC) for 11 years and has more than 25 years' experience of tax disputes of many kinds ranging from large corporates to private clients. He advises on all kinds of difficult matters with HMRC including large scale multi-issue discussions (HRCP), challenges to tax planning, systems and governance issues, risk management, penalties, tax administration and fraud. Simon has represented PwC and ICAEW in relation to the senior accounting officer regime and has considerable experience of helping clients bring themselves up to date and gain favourable risk assessments from HMRC.

Simon is also a trained mediator and has helped pioneer the use of mediation (ADR) with HMRC resulting in successful outcomes for many clients.

Simon has a degree in law from the University of Wales, Cardiff.