PwC LLP

Tax litigation.

Mark leads the Direct Tax Disputes practice. He is one of the UK’s leading specialists in contentious tax (a leading individual in both Legal 500 and Chambers & Partners), having 28 years’ experience in the field. He is a corporate tax specialist and has been involved in some of the most significant tax cases over the last decade including the UK’s only substantive transfer pricing case (DSG Retail) and several groundbreaking EU tax cases (ACT GLO, Philips Electronics, BMW and Stamp Duty GLO).

He has particular experience in group litigation orders (in the context of EU law challenges), tax planning challenges, HRCP cases (the High Risk Corporate Programme), corporate tax appeals, judicial reviews and, in particular, matters of international taxation such as international transfer pricing disputes. He also has an extensive practice advising clients who seek to contest EU state aid decisions in respect of UK taxation matters.

Mark’s practice includes acting for a wide range of clients ranging from blue chip FTSE100 companies, US multinationals, Premier League clubs and public and private businesses based around the world with UK operations. Where PwC acts for a client in respect of their tax affairs, Mark is their first port of call when an enquiry is opened and matters become contentious. He is also regularly called in to advise clients alongside other law firms where clients are looking for an experienced pair of hands to provide additional guidance and strategic oversight.
Mark litigated on behalf of GE in respect of an HMRC clearance which was the largest piece of litigation currently being run by HMRC's Large Business.

Mark litigated the UK’s only substantive transfer pricing case, DSG Retail Limited, and several groundbreaking EU tax law cases (including Philips Electronics and BMW). Recent significant cases include the Stamp Taxes GLO, Alan Anderson, Air Berlin, and Biffin.

Mark is a member of the PwC Tax Dispute Resolution Network, which brings together specialists in tax disputes from across the whole of the global PwC network. He is also a CEDR accredited mediator and has experience of alternative dispute resolution. He has worked for HMRC’s solicitors’ office and has first-hand knowledge of how HMRC handles disputes.

Trained Allen & Overy; qualified 1992.

French.

Mark is a CEDR accredited mediator and has experience of alternative dispute resolution. 

University of Birmingham (LLB Law and French); King’s College, London.

Cycling, running and music.