David works with a range of UK and overseas-based clients, particularly in the financial sector, who need advice on the UK tax implications of their cross-border transactions.
David regularly provides support on tax issues for corporate transactions, securitisations, debt and equity markets work and hybrid financings, and advises on tax dispute resolution. As a member of the Institute of Chartered Accountants and having worked in investment banking before joining Freshfields, David can bring a broader perspective than most other tax lawyers.
Ranked by Chambers UK as an ‘eminent practitioner’, 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.
- Advising UBS on its merger with Credit Suisse.
- Advising State Street on its acquisition of Mizuho Financial Group’s securities services businesses in the US and Luxembourg.
- Advising UK Finance on a banking industry wide challenge by HMRC to the treatment for bank levy purposes of certain deposits protected under the financial services compensation scheme.
- Advising BNP Paribas on its acquisition of AXA Investment Managers.
- Advising Tesco on the sale of its banking operations and the entry into a strategic partnership with Barclays Bank.
- Advising The Boston Consulting Group on its litigation in relation to the tax treatment of its UK partners on their compensation and equity framework.
- Advising Barclays Bank on its litigation with HMRC in relation to the tax deductibility of certain reserve capital instruments issued alongside equity warrants during the financial crisis.
- Advising HMG on the disposal of UK Government Investment’s shareholding in Natwest.
- Advising Glencore (oil and commodity trading) on its dispute with HMRC in respect of diverted profits tax, including its judicial review challenge in the Court of Appeal.
- Advising EDF on the joint venture arrangements with the UK government for the investment in and delivery of the Sizewell C nuclear power station, including on the arrangements for the exit of the Chinese state energy company from the project.
- Advising Rolls-Royce SMR on its partnership with CEZ Group.
- Advising Octopus Energy on the acquisition of a third party's UK and German home energy business.
- Advising Lloyd’s of London on the tax aspects of its landmark reinsurance cover for its Central Fund.
- Advising ReAssure on their acquisition of the savings business of Legal & General.
100 Bishopsgate