Brexit and tax treaties: the US LOB problem
Competent authority agreements between the UK and the US have recently been published addressing the interpretation of certain provisions...
About Me
David is the head of the Freshfields tax practice in London. His financial sector clients find that his unusual (for a tax lawyer) professional background – he is a member of the Institute of Chartered Accountants and has worked at a senior level in investment banking – gives him a detailed insight into their thinking, an understanding of their business requirements and an appreciation of their internal approvals processes.
He works both with UK clients and with foreign-based banks and other financial sector organisations which need advice on the UK tax implications of their cross-border transactions.
He also regularly provides support on taxation issues for the firm’s corporate and finance practices in relation to complex transactions, securitisations, debt and equity markets work and hybrid financings.
His wide experience of complex structured finance transactions means that he can identify pitfalls in proposals before they occur and identify effective proactive strategies to overcome them.
David is known for his ability to present complicated taxation and legal issues in a direct and straightforward way. On international cases, he frequently co-ordinates a team that includes foreign tax lawyers, interpreting and delivering their advice to focus closely on the client’s requirements.
His standing as a UK tax professional is reflected in the fact that he has been asked on a number of occasions to act as an expert witness on UK taxation in foreign tax disputes.
The breadth of David’s expertise, his commitment and his determination to follow every detail of every transaction through to the end mean that he establishes close and lasting client relationships.
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Brexit and tax treaties: the US LOB problem
Competent authority agreements between the UK and the US have recently been published addressing the interpretation of certain provisions...
Impact of Article 50 on references to the CJEU
It was inevitable that the UK courts would start to encounter ‘Brexit based’ arguments and we now have an example of this in a tax...
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