A GAAR FOR THE UK?

BUILDING ON OVERSEAS EXPERIENCE

10 February 2012

OXFORD LAW

The Centre for Business Taxation is grateful to the Oxford Melbourne Law School Research Partnership funded by Mr Allan Myers AO QC for financial assistance with this conference.

Thanks also go to Allen & Overy, McGrigors LLP and the Norton Rose Group for their financial support.

The Centre is also supported by the Economic and Social Research Council and by a number of corporate donors, including several members of the Hundred Group; donors are listed on the Centre’s website www.sbs.ox.ac.uk/centres/tax

The Centre for Business Taxation is an independent research centre of the University of Oxford with the full academic freedom from control resulting from that status. The Centre’s research programme is determined on the basis of academic merit and policy relevance, and is the responsibility of the Director and the Centre’s Steering Committee. The Centre has no corporate views: views expressed in publications produced by the Centre are the responsibility of the authors.

WELCOME

In a time of austerity, the issue of tax avoidance has once again caught the public eye and that of politicians. In December 2010, Graham Aaronson QC was asked by the UK Exchequer Secretary to the Treasury, David Gauke, to conduct a study that would consider whether a General Anti-Avoidance Rule (GAAR) could deter and counter tax avoidance, whilst providing certainty, retaining a tax regime that is attractive to businesses, and minimising costs for businesses and HMRC: a demanding request. Mr. Aaronson, supported in his work by a Study Group, delivered his report in November 2011.

The Aaronson Report proposes a targeted anti-abuse rule, rather than a broad spectrum anti-avoidance rule. It aims to escape some of the problems experienced with GAARs in other jurisdictions. Novel features for the UK, such as a proposed Advisory Panel, bear similarities to institutions elsewhere, but differ in other respects. The proposals do not seek to tackle all activities that might be classified as tax avoidance, but only contrived and artificial schemes. A GAAR cannot be expected to take the place of fundamental policy improvements, or a redraft of the entire tax code, but it can tackle extreme cases.

Unsurprisingly in such a contentious area, the Aaronson Report has had a mixed response, but has been welcomed in some unexpected quarters. The UK statute law is widely regarded as having reached a state of unmanageable complexity and the current UK case law on avoidance is uncertain. Many commentators have recognised the value of targeted proposals designed to deter egregious tax avoidance, whilst providing a framework that could create greater certainty and eventually assist in decreasing complexity. The usual concerns have been expressed about the scope of the proposals and the difficulties of capturing the concepts in legislation.

The Government is currently discussing the implications of the Aaronson proposals with business and tax groups and has promised to respond fully at Budget 2012, setting out its plans for further, formal public consultation, if it considers it appropriate to take these ideas forward.

This conference is a contribution to this on-going process. The Centre has brought together Graham Aaronson, members of his Study Group and other UK experts to discuss these issues with leading authorities on the GAARs of other jurisdictions. Attention will be focused on lessons that might be learned from outside the UK, not merely in terms of the drafting of the rules, but also in respect of the processes and institutions set up to manage their application.

PROGRAMME

08:30 - 09:00 Registration and coffee Welcome Professor Michael Devereux, Director, Centre for Business

Taxation Session I

A GAAR FOR THE UK? Chair: Sir Launcelot Henderson, Judge of the Chancery

Division of the High Court of Justice

09:10 - 09:30 Professor Judith Freedman, Oxford University Law Faculty and Director of Legal Research, Centre for Business Taxation, University of Oxford

Background and objectives of the conference

09:30 - 10:00 Graham Aaronson QC, Pump Court Tax Chambers The Aaronson Report: a unique and tailor made proposal

10:00 - 10:20 Philip Baker QC, Gray’s Inn Tax Chambers International implications of the GAAR

10:20 - 10:40 Richard Lyal, Legal Adviser, European Commission The EU and the GAAR

10:40 - 11:00 John Bartlett, Group Head of Tax, BP PLC UK competitiveness and the GAAR

11:00 - 11:25 Coffee Session II

Chair: Sir Launcelot Henderson

OVERSEAS GAARS – LESSONS FOR THE UK

11:25 - 11:45 Professor David G. Duff, University of British Columbia Faculty of Law, Canada

11:45 - 12:05 Professor Ann O’Connell , Melbourne Law School Australia

12:05 - 12:25 Professor Craig Elliffe, University of Auckland Business School New Zealand

12:25 - 12:45 Ed Liptak, Consultant South African Revenue Service (with responsibility for GAAR) South Africa

12:45 - 01:15 Questions and discussion of morning sessions

01:15 - 02:00 Lunch Session III (i)

Chair: Howard Nowlan, formerly Tax Partner at Slaughter & May, part-time Tribunal Judge in the First-Tier Tribunal (Tax Chamber) and deputy judge in the Upper Tribunal (Tax).

OVERSEAS GAARS – LESSONS FOR THE UK II

02:00 - 02:20 Professor Graeme Cooper, University of Sydney The problems of taxing by analogy

02:20 - 02:40 Emer Hunt, University College Dublin The GAAR as a last resort: the Irish experience

Session IV

Chair: Howard Nowlan

A GAAR PANEL

02:40 - 03:00 Hon Justice GT (Tony) Pagone, Judge in Charge of the Commercial Court of the Supreme Court of Victoria, Professorial Fellow of the Melbourne Law School (has served as member of the Australian GAAR Panel)

03:00 - 03:20 Wayne Adams, Canadian Tax Foundation, formerly Chair of the GAAR committee at the Canadian Revenue Agency

03:20 - 03:40 Malcolm Gammie QC, One Essex Court, Research Director, Tax Law Review Committee; part time Judge of the First-tier and Upper Tax Tribunals

03:40 - 04:00 Discussion of the afternoon sessions

04:00 - 04:20 Tea

CONCLUDING COMMENTS AND THE WAY FORWARD

Chair: Michael Devereux, University of Oxford Centre for Business Taxation

04:20 - 04:40 Chris Davidson, Head of Anti-Avoidance Group, HMRC How is the Government responding to the Aaronson Report?

04:40 - 05:00 The Rt Hon Lord Hoffmann, formerly Lord of Appeal, Non-Permanent Judge of the Court of Final Appeal of Hong Kong, Visiting Professor Oxford Law Faculty.

Summing up

05:00 - 05:40 Panel discussion and questions and comments from the floor. Panel: Graham Aaronson QC, John Bartlett, Professor Judith

Freedman, Lord Hoffmann and, Professor John Tiley QC, Emeritus Professor and Director of the Centre for Tax Law, University of Cambridge

05:40 Conference close

PROGRAMME continued...

BIOGRAPHIES

Graham Aaronson QC

After reading Law at Cambridge, Graham Aaronson started his professional life at the Bar at 4 Essex Court (now Essex Court Chambers) prior to moving to the leading tax chambers 4 Pump Court (now called Pump Court Tax Chambers), in order to specialise in revenue law.

He became a QC in 1982 and from that time he has specialised exclusively in the field of commercial taxation. His landmark cases include BMBF v Mawson and Hoechst. Alongside his normal professional practice he served as the first chairman of the Tax Law Review Committee (and as such initiated the process which led to the tax law rewrite), chairman of the Revenue Bar Association and part time Special Commissioner.

Away from his practice he worked for four years as the managing director of quoted plastics engineering company, and three years as policy adviser on taxation at the Israel Treasury (as part of the team drafted to deal with Israel’s chronic hyper-inflation).

In December 2010, Graham was asked by HM Treasury to lead a study , together with an Advisory Committee, to consider whether a general anti-avoidance rule should be introduced into the UK. His report was published on the HM Treasury website in November 2011 (http://www.hm-treasury.gov.uk/d/gaar_final_report_111111.pdf).

Wayne Adams

Wayne Adams, now working at the Canadian Tax Foundation, recently retired from the Canada Revenue Agency (CRA), where he was employed from 1977-2011. Wayne graduated from the University of Waterloo, where he specialised in Accounting. At the CRA he was Director General, Legislative Policy (1997 – 2004) and then took up the post of Director General, Income Tax Rulings, and Chief Technical Officer for the Canada Revenue Agency (2004 -2011) He was also the Chair of the General Anti-Avoidance Rule (GAAR) Committee from 2004-11, having been a member of that Committee since 1995. He was a Governor of the Canadian Tax Foundation from 2006- 2010.

Wayne was the Canadian Delegate to the Organization for Economic Co-operation and Development (OECD) Working Party on Tax Avoidance and Tax Evasion (1997 – 2004) and is a frequent speaker on current issues at the Canadian Tax Foundation, the International Fiscal Association and to professional groups. He has appeared before Parliamentary Committees to explain technical issues in cross-border financing, the purpose of the General Anti-Avoidance Rule, and the need for retroactive legislative amendments to the GAAR in 2004.

Philip Baker QC

Philip Baker is a barrister and QC practising from Grays Inn Tax Chambers. He was called to the bar in 1979, began practising in 1987 and took silk in 2002. He specialises in international tax issues, with a particular emphasis on double tax conventions, and on European Union law and taxation. He has a particular interest in the European Convention on Human Rights and taxation.

Before moving into practice, he taught law for seven years at the School of Oriental and African Studies, London University. He was subsequently a visiting professorial fellow at Queen Mary University of London, and is now a senior associate fellow of the Institute of Advanced Legal Studies, London University. He is the author of ‘Double Taxation Conventions’ and ‘International Tax Law’ and the editor of the ‘International Tax Law Reports’ and joint editor of the British Tax Review.

John Bartlett

John has been Head of Tax for the BP Group since 2006. He is responsible for ensuring that BP complies, with all of the tax laws and regulations in the jurisdictions in which it conducts business. John is based in London and leads a team of 450 tax professionals working in more than 30 countries. He is a member of the Group Chief Financial Officer’s Leadership Team. His role in BP is focused on building the capability of this large international team to meet increasingly challenging fiscal and regulatory compliance obligations; together with the development of tax mitigation and risk management plans that support the Group’s Strategy and Values.

John joined BP in 1988 after 15 years as an Inspector of Taxes in the UK Inland Revenue. He has held a variety of roles in BP, including that of International Finance and Tax Manager, Controller of North Sea Taxes, Head of UK and Business Taxes and CFO for BP’s Exploration & Production Segment. John represents BP and the UK Oil industry on fiscal issues with the OECD, the International Fiscal Association (IFA), and the Confederation of British Industry (CBI). He is currently a member of HMRC’s Business Tax Forum, HM Treasury’s Corporate Tax Reform Committee and a member of the UK GAAR Study Advisory Committee.

Graeme Cooper

Graeme Cooper is Professor of Taxation Law at Sydney University and a consultant to Greenwoods & Freehills. He also teaches at the University of Virginia Law School and is a Visiting Professor at Katholieke University, Belgium. He has worked as a consultant on tax projects for the OECD, IMF, World Bank, Australian Treasury, Australian Taxation Office, the Board of Taxation and the Australian National Audit Office. He is a frequent speaker at national and international tax conferences, the author of several books and many articles in Australian and international journals. His published work includes several pieces in Australia and the US on the design, structure and operation of GAARs.

Chris Davidson

Chris Davidson CBE is head of HMRC’s Anti-Avoidance Group and is leading HMRC’s team that is reviewing the GAAR proposal. He has extensive experience of tax policy and administration in leadership, investigation and technical roles, having joined the Inland Revenue in 1976. He led the policy team that developed the disclosure rules in 2004, and he also led the OECD Tax Intermediaries study in 2006-2007. Until last year, Chris was Deputy Director in HMRC’s Large Business Service where he led operational work on banks and insurance companies, including the introduction of the code of practice for banks and the implementation of the bank payroll tax.

Michael Devereux

Michael Devereux is Director of the Oxford University Centre for Business Taxation, Professor of Business Taxation, Associate Dean of Research, at the Saïd Business School and Professorial Fellow at Oriel College, Oxford. He is Research Director of the European Tax Policy Forum, and Research Fellow of the Institute for Fiscal Studies, the Centre for Economic Policy Research and CESifo. He is Vice-President of the International Institute for Public Finance, and assistant editor of the British Tax Review and sits on the Editorial Board of the World Tax Journal. Professor Devereux is a member of the Business Forum on Tax and Competitiveness, chaired by the Exchequer Secretary.

David Duff

David G. Duff is Professor of Law and Associate Dean at the University of British Columbia Faculty of Law, where he works on a number of areas of law including taxation. Prior to joining UBC Law in 2009, Professor Duff was a member of the University of Toronto Faculty of Law for thirteen years. Before that, he was a tax associate at the Toronto office of Stikeman, Elliott. He was also a researcher with the Ontario Fair Tax Commission (1991 to 1993) and a tax policy analyst with the Ontario Ministry of Finance (1993 to 1994). He has been a visiting scholar at the Universities of Auckland , McGill, Oxford , and Sydney, and is a Research Fellow of the Monash University Taxation Law and Policy Research Institute, an International Research Fellow of the Oxford University Centre for Business Taxation, and a member of the Tax Academy of the Americas.

David has published numerous articles on tax law and policy, is the lead author on a textbook/casebook on Canadian income tax law, and has co-edited a book on tax avoidance in Canada . He has written several articles on tax avoidance and the Canadian General Anti-Avoidance Rule (GAAR) and was cited in the Supreme Court of Canada’s most recent GAAR decision in Copthorne Holdings Ltd. v. Canada, 2011 SCC 63.

Craig Elliffe

Craig Elliffe is a chartered accountant. He is Professor of Taxation Law and Policy and director of the Master of Taxation Studies at the University of Auckland Business School, which he joined in 2008 after 14 years as a tax partner at KPMG and 8 years as a tax partner at Chapman Tripp (New Zealand’s largest law firm), to which he continues to act as a consultant. As a tax partner, Craig was involved in substantial recent litigation concerning the application of the New Zealand general anti-avoidance rule (GAAR). As a consultant he has been involved in advising clients and Inland Revenue (as an independent expert) on anti-avoidance disputes. As an academic he has numerous recent articles on the New Zealand GAAR published in the New Zealand Journal of Taxation Law and Policy, the New Zealand Business Law Quarterly, and the New Zealand Universities Law Review.

Craig was a member of the committee responsible for the report entitled “Improving the Operation of New Zealand’s Tax Avoidance Laws” and organised a high level symposium at the University of Auckland in November 2011 on the same topic, chaired by the President of the New Zealand Court of Appeal, the Honourable Justice Mark O’Regan, with speakers from Inland Revenue, the New Zealand Institute of Chartered Accountants and the New Zealand Law Society.

Judith Freedman

Judith Freedman is Professor of Taxation Law at the Oxford University Faculty of Law and Director of Legal Research at the Oxford University Centre for Business Taxation and an Adjunct Professor in the Australian School of Taxation and Business Law, Australian School of Business, University of New South Wales. Previously she was a solicitor in the corporate tax department of Freshfields and then lectured at the London School of Economics. Her inaugural lecture in Oxford was entitled Defining Taxpayer Responsibility: In Support of a General Anti-Avoidance Principle and was published in the ‘2004 British Tax Review’. She has published and lectured widely on a variety of tax and corporate law issues. She is general editor of the ‘British Tax Review’ and on the editorial boards of the Canadian Tax Journal, the Australian Tax Review, the e-Journal of Tax Research , the Tax Journal , PLC Tax and The Modern Law Review. She is a member of the Tax Law Review Committee of the Institute for Fiscal Studies (IFS), and of the Council of the IFS and also serves on the consultative committee on small business taxation of the Office of Tax Simplification. Judith was a member of the UK GAAR Study Advisory Committee.

Malcolm Gammie QC

Malcolm started his tax career in the City with Linklaters & Paines. After a period working on tax policy at the CBI, he was among the first lawyers to work in the tax field with a leading accounting firm. At KMG Thomson McLintock (now part of KPMG), he was the first Director of the firm’s National Tax Office and then its Director of National Tax

Services. In 1985 he returned to Linklaters & Paines and from 1987 to 1997 was one of its senior tax partners. He moved to the Bar in 1997 to concentrate on tax litigation and advisory work and took silk in 2002.

In recent years Malcolm has represented the Revenue in a number of tax avoidance cases that have deployed successfully the Ramsay principle. Malcolm is also the Research Director for the IFS’ Tax Law Review Committee. In that capacity he was responsible for overseeing the Committee’s work in 1998 on a proposed GAAR and its more recent work on legislative approaches to tax avoidance up to 2009. He is a part time Judge of the First-tier and Upper Tax Tribunals and a member of the Tax Professionals’ Forum chaired by the Exchequer Secretary.

Sir Launcelot Henderson

Sir Launcelot Henderson (The Honourable Mr Justice Henderson) has been a Judge of the Chancery Division of the High Court since January 2007. He has a particular interest in tax law and procedure, having served as a Standing Junior Counsel (Chancery) to the Inland Revenue from 1987 to 1992 and then as Standing Junior Counsel to the Inland Revenue from 1992 to 1995. After taking Silk, he continued to spend the greater part of his time as a QC (from 1995 to 2006) advising and representing the Crown in direct tax cases.

As a judge, he covers the full range of the work of the Chancery Division, but has also had responsibility for major group litigation involving the interaction between domestic corporate tax law and the law of the EU (including, in particular, the first instance hearings in FII, Thincap and ACT (Classes 2 and 4), and further group litigation in the field of VAT (Chalke, and a forthcoming judgment on Investment Trusts). Tax avoidance cases in which he has been involved as an advocate or a judge include McGuckian, Willoughby, D’Arcy, Bank of Ireland Britain Holdings Ltd and Tower MCashback (where he was upheld by the Court of Appeal but overruled by the Supreme Court).

Launcelot Henderson is a Bencher of Lincoln’s Inn, a Trustee of the Samuel Courtauld Trust and a Distinguished Fellow of All Souls College, Oxford. He is a member of the Civil Procedure Rules Committee.

Lord Hoffmann

Lord Hoffmann was a Lord of Appeal in Ordinary from 1995 to 2009 and is now a Non-Permanent Judge of the Court of Final Appeal of Hong Kong and a Visiting Professor at the Oxford Law Faculty. He was a member of the UK GAAR Study Advisory Committee.

Emer Hunt

Emer Hunt graduated from Trinity College Dublin and received an LLM in tax from The London School of Economics. She qualified as a solicitor in Ireland, and in England and Wales. She has worked in London and New York for Allen & Overy and Slaughter and May, before returning to Dublin to teach in University College Dublin. Emer has been interested in the effectiveness of a general anti-avoidance provision for some time. When she left Ireland in 1993, Ireland had recently adopted a GAAR but, on her return in 2006, she was interested to see that the response had been muted. It was only in late 2011 that the Irish Supreme Court first considered the Irish GAAR in Revenue Commissioners v O’Flynn Construction & ors [2011] IESC 47 . This case is currently the subject of much discussion in tax circles in Ireland.

Ed Liptak

Ed Liptak is currently a senior specialist with the Legal and Policy Division of the South African Revenue Service. His responsibilities include assisting SARS’s Large Business Centre in identifying and developing cases under South Africa’s GAAR. Ed was a co-author of SARS’s Discussion Paper on Tax Avoidance, which was released in November 2005, as well as South Africa’s current GAAR, which was enacted in October, 2006. Ed is participating in the Conference on an individual basis and not as a SARS representative. Any views expressed by him are entirely his own.

Richard Lyal

Richard Lyal is a member of the Legal Service of the European Commission, where he has for several years been responsible for tax issues. He has been agent for the Commission in more than 400 cases before the EU courts, the EFTA Court and the European Court of Human Rights, mainly in the fields of competition, State aid and taxation (both direct and indirect). His interest in GAAR stems from his experience as agent for the Commission in the Halifax and Cadbury Schweppes cases before the European Court of Justice. He is joint author (with Paul Farmer) of EC Tax Law, OUP 1994 (new edition in preparation).

Howard Nowlan

Howard Nowlan was a corporate tax partner in Slaughter and May from 1976 until his retirement in late 2004. Since that date he has worked as a part-time Special Commissioners and Chairman of the VAT and Duties Tribunal, and is now a fairly active part-time Tribunal Judge in the First-tier Tax Tribunal, and a deputy judge in the Upper Tax Tribunal. He was a member of the UK GAAR Study Advisory Committee

Ann O’Connell

Ann O’Connell is Professor of Taxation and Co-Director of Taxation Studies at the Melbourne Law School. She has published widely on taxation and teaches taxation in the undergraduate and postgraduate programs at Melbourne Law School. She is a Visiting Fellow at the University of Cambridge and Special Counsel at Allens, Arthur Robinson. She is also a member of the Advisory Panel to the Board of Taxation and an external member of the Australian Tax Office Public Rulings Panel.

Justice GT (Tony) Pagone

Justice GT (Tony) Pagone is Judge in Charge of the Commercial Court of the Supreme Court of Victoria and a Professorial Fellow of the Melbourne Law School. He holds degrees from Monash University and the University of Cambridge. Justice Pagone is the author of ‘Tax Avoidance in Australia’ (Fed Press, 2010) and teaches Tax Avoidance and Planning in the Masters program at the Melbourne Law School. Prior to becoming a judge he appeared in many of the leading tax avoidance cases before the Federal Court and High Court. Justice Pagone held the position of Special Counsel to the Australian Tax Office (ATO) in 2003. Justice Pagone has been an external member of the Australian GAAR Panel and has previously appeared before the Panel as a barrister.

John Tiley

John Tiley read law at Lincoln College, Oxford, under Brian Simpson. After brief teaching stints at Oxford and Birmingham he joined the law faculty - and became a Fellow of Queens’ College, Cambridge in 1967. The faculty asked him to teach tax law and he has remained involved with that subject ever since. He retired from his university post in 2008 but remains closely involved with the Faculty and with the Cambridge Centre for Tax Law which he helped found in 2001. His book, Revenue Law was first published in 1976. He has been much involved with the problems of tax avoidance and case law. He became a Reader in 1987 and a Professor in 1990. He is a Fellow of the British Academy and a QC (hon). He served as an Assistant Recorder and then Recorder between 1984 and 1998 and was a member of the UK GAAR Study Advisory Committee.

LIST OF PARTICIPANTS

Name Affiliation

Graham Aaronson QC Pump Court Tax Chambers

Barbara Abraham Red Bee Media Ltd

Ruth Adams Sub Saharan Consulting Group

Wayne Adams Canadian Tax Foundation

Michael Akpomiemie London School of Economics

and Political Science

Benjamin Alarie University of Toronto

Mark Alderton HMRC

Samuel Aldridge ICAP Plc

Philip Baker QC Gray’s Inn Tax Chambers

Stephanie Ball Grosvenor Group Limited

Antonia Balsom SJ Berwin

John Bartlett BP PLC

Chris Bates Norton Rose LLP

Naomi Belcher Practical Law Company

Alessandro Belluzzo Belluzzo & Associati LLP

Daniel Berry HMRC

Michael Blackwell LSE

Helen Blenkinsop Friends Life Group

Hayley Book GE

Tracey Bowler Tax Law Review Committee

Mark Braude Braude Osborne Clarke

Jonathan Bremner Pump Court Tax Chambers

Ian Brimicombe AstraZeneca

David Bunting HMRC Solicitor’s Office

James Burton Allen & Overy LLP

Iain Campbell Personal

Name Affiliation

Francesco Carelli University of Oxford

Ian Carnochan HM Revenue & Customs

Tom Cartwright McGrigors LLP

Lydia Challen Allen & Overy LLP

Brian Chapman BAE Systems plc

Kika Christodoulou King’s College London

Evangelia Christou King’s College London

Louise Coleman LexisNexis

Shane Collery 18 Red Lion Court / IALS

Carolyn Comben HMRC

Gary Coombs HMRC

Natalie Coope LexisNexis

Graeme Cooper University of Sydney

John Cornelius-Joyce Anglia Ruskin University

George Crozier

Rita Cunha IALS, University of London

Saajid Dauho King’s College London

Chris Davidson Head of Anti-Avoidance Group, HMRC

Edward Davies King’s College London

Reinout de Boer Stibbe / University of Amsterdam

Nicholas Dee ncdee.tax

Michael Devereux Centre for Business Taxation

Ian Dowson William Garrity Associates Ltd

Gerardine Doyle University College Dublin

David Duff University of British Columbia

Pat Dugdale Olswang LLP

James Duncan HMRC

Brad Edwards Australian Taxation Office

Craig Elliffe University of Auckland

Chris Evans ATAX, UNSW

Name Affiliation

Megumi Ezaki University of Oxford

Anne Fairpo 13 Old Square Chambers

Jane Faulkner HMRC

Massimo Ferrari Vodafone

Ian Ferreira Weil Gotshal and Manges

Anna Florczak London University

Hartley Foster Olswang LLP

Catherine Francis Clifford Chance LLP

Claire Francis HMRC

Jane Frecknall-Hughes The Open University School of Law

Judith Freedman Centre for Business Taxation

Alexandra Galloway HM Treasury

Malcolm Gammie QC One Essex Court

Colin Garwood IHG Plc

Silva Gashi King’s College London

Eile Gibson Tower Bridge Tax Practice

Andrew Goodall Tax Journal (LexisNexis)

Natalia Gordin

Laurence Gormley University of Groningen

Andrew Gotch Tax Fellowship

Laura Gould SJ Berwin LLP

Ashley Greenbank Macfarlanes LLP

Joanna Grice HMRC

Mark Groom Deloitte

Dave Hartnett HMRC

Werner Haslehner London School of Economics

Ian Hayes European Fiscal Services

Katerina Heal Debevoise & Plimpton LLP

Name Affiliation

Launcelot Henderson Judge of the Chancery Division

of the High Court of Justice

Iain Hill Pricewaterhousecoopers

Matthew Hodkin Norton Rose LLP

Lord Hoffman Formerly Lord of Appeal

Vanessa Houlder Financial Times

Peter Hoyle King’s College London

David Hughes Allen & Overy LLP

Ann Humphrey Ann L Humphrey Solicitors

Mark Humphreys Smith & Nephew

Emer Hunt University College Dublin

Richard Ireson HMRC

David Jacob Practical Law Company

Michael Jacobs Jacobs Intrinsic Strategy

Grant Jamieson RBS

Paula Jarnecki HMRC

Vella John Centre for Business Taxation

Mark Johnson OECD

Nick Johnson Smith & Nephew

Tim Johnson American UK Tax Solutions

David Johnston Oaktree Capital Management

David Jordorson Marsh & McLennan Companies

Artem Kadikov University of Oxford

Bilicka Kat Centre for Business Taxation

Philipp Kepper University of London

Serdar Kilic University of London

Judith Knott CT, International and Anti Avoidance

Giedrius Kolesnikovas IALS, University of London

Anna Kubiak Best Buy Europe

Natalie Lee University of Southampton

Name Affiliation

Sunjoo Lee Queen Mary University of London

Esther Lemmon Allen & Overy LLP

Zoe Leung-Hubbard HMRC

Ed Liptak Consultant South African

Revenue Service

Glen Loutzenhiser University of Oxford

Alison Lovejoy

Sandeep Loyal King’s College London

Richard Lyal European Commission

Fionnuala Lynch Reed Smith LLP

Graeme Macdonald

Giorgia Maffini Centre for Business Taxation

Venugopal Mahapatra University of Oxford

Alex Makinson King’s College London

Jeff Mann University of Queensland

Jennifer Maskell Allen & Overy LLP

Osita Mba HMRC

Doreen McBarnet University of Oxford

Ray McCann McGrigors LLP

Daniel McCarthy University of Oxford

Hui Ling McCarthy Gray’s Inn Tax Chambers

Jane McCormick KPMG

Mary Mcdonagh Kilsby & Williams

Neil McKnight Taylor Wessing

Al Mead Alchemy

Kassim Meghjee Steptoe & Johnson

Charles Middleton The British Land Company PLC

Nicolas Miguel Paris Descartes University

Pete Miller The Miller Partnership

Ioanna Mitroyanni European Commission

Name Affiliation

Jeremy Moore Grosvenor Group Limited

Harriet Morgan Reed Smith LLP

Gregory Morris University of Exeter

William Morris GE

Tim Murrills ExxonMobil

Irfan Najam Abacus Tax

Harriet Nantumbwe Queen Mary University of London

Sameera Nathoo EnTech USB Ltd

Tom Neale European Commission

Dan Neidle Clifford Chance LLP

Eugene Nizeyimana Sub-Saharan Consulting Group

Howard Nowlan Part-time Tribunal Judge in the

First-Tier Tribunal (Tax Chamber)

Lynne Oats University of Exeter

Gerard O’Callaghan Credit Suisse

Ann O’Connell Melbourne Law School Australia

Adrian Ogley Contracts Consultancy Ltd

Robert O’Hare LexisNexis

Abimbola Olowofoyeku Brunel University

Rodrigo Ormeño University of Exeter Business School

Sarah Osprey University of Oxford

Hon Justice GT (Tony) Pagone Judge in Charge of the Commercial Court

of the Supreme Court of Victoria

Philip Peberdy Unilever

Christos Perikleous King’s College London

Emil Pietras University of Cambridge

Sarah Priestley Weil, Gotshal & Manges

Simon Pudge RBS

Ian Quelch HMRC

Charlotte Redcliffe Centrica plc

Name Affiliation

Chris Reece

Andrew Rein HMRC

Sabrina Ricci GME SpA

Jon Richardson Pricewaterhousecoopers LLP

Helen Rogers Oxford Brookes Business School

Vadim Romanoff University of London

Paulo Rosenblatt IALS, University of London

Pier Marco Rossi Merli Belluzzo and Associati LLP

Ian Roxan London School of Economics

and Political Science

Chas Roy-Chowdhury ACCA Global

Paula Ruffell HMRC

Benedicte Sage-Fuller University College Cork

Ilias Sakellariou University of London

David Salter University of Warwick

Chris Sanger Ernst & Young

Martin Sans The Tax Practice

Danilo Santobino University of Oxford

Angela Savin Norton Rose LLP

Tim Schmidt-Eisenlohr Centre for Business Taxation

Jonathan Schwarz Temple Tax Chambers

Tom Scott IFA UK branch

Heather Self McGrigors LLP

Dhiren Shah Inttax

Assiya Shalabayeva Gibson, Dunn and Crutcher LLP

Shahram Sharifi London University

Deeksha Sharma University of Oxford

Musa Sherif SAS / UoL

Iain Shore Taylor Wimpey

Edwin Simpson Oxford University

Name Affiliation

Garry Siveyer HM Treasury

David Smith International Power Plc

Camilla Spielman Eversheds

David Stainer Allen & Overy LLP

Paul Stainforth LexisNexis

Anne Stark HMRC

Mark Steptoe HMRC

Dominic Stuttaford Norton Rose LLP

Inga Sviderskiene King’s College London

Aurell Taussig Herbert Smith LLP

David Taylor Freshfields Bruckhaus Deringer

Alun Thomas Chartis Insurance

John Tiley University of Cambridge

Franz Tomasek South African Revenue Service

Annemarie Tuohy Marsh McLennan

Caroline Turnbull-Hall PwC

Grahame Turner Institute of Advanced Legal Studies

Jeremy Tyler HMRC

Agne Uloze King’s College London

John Vella Centre for Business Taxation

Tim Voak Tesco Plc

Kevin Waller HMRC

Tom Wesel King’s College London

John Whiting Chartered Institute of Taxation

David Williams Moore Stephens LLP

Mike Williams HM Treasury

Paul Williams Friends Life

Camilla Woods HMRC

Vanessa Woodward HMRC

Carlene Wynter University of Exeter

Name Affiliation

Simon Yates Travers Smith

Susan Yee King’s College London

Anzhela Yevgenyeva Centre for Business Taxation

Ian Young ICAEW

Recep Yucedogru Nottingham Business School

Karolina Zastawniak Aston Court Chambers International SA

Xiaoyu Zhai King’s College London

Hui Min Zhang Institute of Advanced Legal Studies

Ferdinando Zullo Independent Consultant

Anton Zykov KPMG

Oxford University Centre for Business Taxation, Saïd Business School, Park End Street, Oxford OX1 1HP

Tel. 01865 288904 www.sbs.ox.ac.uk/centres/tax