Tax disputes resolution group.

Adam is a partner and head of RPC’s tax disputes group. He is also an accredited mediator and advises on a wide range of contentious tax issues (both direct and indirect taxes), including HMRC enquiries and criminal investigations, litigation before the Tax Tribunals and the Higher Courts.

Notable cases include: R v IRC ex parte Mark Basil Andrew Lorimer (No 2) [2000] STC 751 – Judicial Review application relating to HMRC’s information powers and legal professional privilege; Laird Group Plc v CIR [2003] 4 All ER 669 – whether payment of a dividend was a ‘transaction in securities’ within section 703 ICTA 1988; Robert Gains-Cooper v Commissioners for HMRC (2006) Sp C No 00568 – residency and domicile; test claimants in the Thin Cap Litigation v CIR (2007) Case C-524/04 – whether the UK’s tax provisions in relation to thin capitalisation were in breach of the EC Treaty; Pirelli Cable Holding NV & Ors v Revenue & Customs Commissioners [2008] STC 144 – whether non-resident companies were entitled under the relevant double taxation agreements to tax credits on the subsequent payment by a UK subsidiary of mainstream corporation tax.

Farringdon School; Middlesex University; College of Law (Lancaster Gate); LLB Hons (1987); Law Society Finals (1988).