About
Edward is based in the firm’s London office and his practice focuses on tax litigation, investigations and disputes, across all sectors and taxes, alongside public and private M&A transactions and advisory work.
He has extensive experience of high value, complex disputes, covering in particular
- transfer pricing and diverted profits tax (DPT);
- the deductibility of payments, including challenges under purpose-based anti-avoidance rules;
- behavioural penalties and HMRC’s COP8 procedure; and
- appeals before the UK tax tribunals covering a range of UK domestic tax issues.
Additional Information
- Advising Gallaher Limited on a dispute concerning whether the tax treatment of a cross-border intra-group asset transfer is in breach of EU law, which was ultimately referred to the Court of Justice of the European Union.
- Advising various groups on disputes relating to the corporation tax treatment of their UK financing arrangements, including “unallowable purpose” and thin capitalisation challenges.
- Advising various multinational clients on complex, high value disputes relating to transfer pricing, diverted profits tax (DPT), controlled foreign company (CFC) and permanent establishment risk.
- Advising on petroleum revenue tax and capital allowances enquiries and disputes in the energy sector.
- Advising Glencore on its dispute with HMRC in respect of transfer pricing and diverted profits tax.
- Advising large corporates on tax-related contractual disputes.
Edward Buxton
Senior Associate
London Office
100 Bishopsgate
EC2P 2SR London