PROFILE

Nahuel has been an Associate at JHA since joining the firm in 2021.

His practice covers contentious matters, particularly tax disputes. Before joining JHA, he worked as an Associate for a law firm in Chile for almost 3 years, focusing on tax advice and tax litigation, representing multinational and local companies before the tax authority and at all levels of Chilean courts and tax tribunals. Nahuel also previously worked as a lecturer at Pontificia Universidad Catolica de Chile, teaching international law, and as a paralegal at a law firm, focusing on corporate and civil matters.

In 2019, Nahuel published an article on the tax treatment of charitable donations in Chile in Tax Notes International. Since 2018, he has participated as a judge in the Philip C. Jessup International Law Competition, the largest moot court competition in the world. He speaks English, Spanish and Portuguese.

PROFESSIONAL QUALIFICATIONS

Admitted as an abogado in Chile in 2018.

EDUCATION

London School of Economics and Political Science – LLM in Taxation; LSE Master’s Award.

Pontificia Universidad Catolica de Chile – LLB; Miguel Cruchaga Award for International and Comparative Law; Matricula de Honor Award.

RELATED ARTICLES

SHORT CASE REPORT FTT DECISION – ‘MTIC’ FRAUD – KITTEL TEST PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)

  1. A so-called “MTIC case”, in which HMRC alleged knowledge or means of knowledge of fraud.  The taxpayer, PTGI, denied those states of knowledge.  After a relatively lengthy trial, the Tribunal allowed the appeal of PTGI.
  2. The decision represents a good reminder that HMRC’s “MTIC” decision-making mould is not a “one size fits all”, unbeatable formula at the Tribunal.  The Tribunal will robustly analyse HMRC’s (usually) inference-led allegations.

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HMRC consultation on the OECD mandatory disclosure rules

HMRC has published a consultation on draft regulations to implement the Organisation for Economic Cooperation and Development (OECD) rules on mandatory disclosure of certain avoidance arrangements. Helen McGhee and Nahuel Acevedo-Peña explain the background to the new rules and their implications.

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S&S Consulting Services (UK) Ltd v HMRC: Can a company be re-registered for VAT pending appeal?

On 26 November 2021, the High Court of Justice issued its judgment in S&S Consulting Services (UK) Ltd, R (On the Application Of) v HM Revenue and Customs [2021] EWHC 3174. The case concerned the issue of availability of injunctive relief in the context of VAT deregistration appeals in the First-tier Tribunal (“FTT"). S&S also made an application for judicial review of HMRC’s decision to deregister it for VAT, which at the time of the hearing, had not yet been considered on the papers.

HMRC cancelled S&S’s VAT registration because it concluded that the company had been principally or solely registered to abuse the VAT system by facilitating VAT fraud. S&S denied any wrongdoing and claimed that it might become insolvent before the hearing of its appeal as a result of the deregistration.

It was also common ground that although S&S had lodged an appeal to the FTT, the FTT had no power to require HMRC to re-register S&S by way of interim relief pending the outcome of the appeal. S&S made an application to the High Court for relief.

Held: Application rejected.

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