Michael has been a partner JHA since its inception. He has more than 20 years of litigation experience and for more than 15 years he has specialised in tax related disputes. He handles complex high value cases, often involving foreign jurisdictions.
Michael has represented clients at all levels of the UK courts and tax tribunals, as well as before the Court of Justice of the European Union. He has particular experience in running Group Litigation Orders, having acted on most of the tax-related GLOs involving challenges to UK tax legislation based on EU law infringements.
He writes frequently for The Tax Journal and other legal and tax publications.
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.’
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
Scotch Whisky Association: justifying barriers to trade
The recent judgment of the Court of Justice in Scotch Whisky Association and Others v Lord Advocate and Advocate General for Scotland (C-333/14) (23 December 2015) provides further guidance on how national courts in the EU should review legislation restricting trade.Read More