Michael has been a partner JHA since its inception. He has more than 20 years of litigation experience and for much of that time his practice has focused on tax disputes. He has experience in dealing with enquiries and investigations, and of running litigation at all levels of the United Kingdom’s Tax Tribunals, domestic courts and European Courts.
In addition, Michael advises on a wide variety of commercial and intellectual property disputes, often for clients in the creative industries.
Admitted as a solicitor in England and Wales, 1997
College of Law – LPC
University of Cambridge – BA
Michael has received numerous recommendations. The Legal 500 UK has recognised Michael from 2009 to the present, alongside the tier one ranking accorded to JHA’s contentious tax team, since the firm’s inception in 2013. He has been a top ranked partner in Chambers UK for Contentious Tax from 2008 to the present. The most recent edition says Michael is ‘noted for his expertise in high-value tax disputes. He has a wealth of experience in international tax disputes and is adept at handling matters in non-UK jurisdictions.’
Post-Prudential: Decision released by the FTT
On 8 December 2021, judgment in the Post Prudential Group Litigation was handed down by the First-tier Tribunal (Tax Chamber) (“FTT”). These were appeals and applications for closure by approximately 200 taxpayers, who had made a variety of claims seeking repayment of unlawful DV tax imposed on dividends received from foreign portfolio holdings. The FTT considered the validity of these various statutory claims following decisions in test cases in the CFC & Dividend GLO, namely Claimants in Class 8 of the CFC and Dividend Group Litigation v Revenue and Customs Commissioners  EWHC 338 (Ch),  1 WLR 5097 (“Class 8”) and Prudential Assurance Co Ltd v HMRC  UKSC 39;  AC 929 (“Prudential SC”).Read More
Swedish Cross-border Group Relief Cases – AG Kokott’s Opinions – Swedish rules compatible with EU Law
Advocate General (AG) Kokott has issued her opinion in two cases concerning claims for group relief made by Swedish companies for the losses of wholly-owned direct and indirect subsidiaries established in other EU Member States. The opinions are in line with the AG’s consistent approach that the “no possibilities” test in Marks & Spencer (C-446/03)Read More
HMRC introduces a new Profit Diversion Compliance Facility
HMRC appears to have concluded that significant numbers of businesses have yet to align their transfer pricing policies with the transfer pricing outcomes of the OECD/G20 BEPS Project. HMRC has accordingly introduced a new Profit Diversion Compliance Facility (PDCF) to encourage multinational enterprises (MNEs) to make voluntary disclosures about any transfer pricing arrangements that fallRead More