Simon is a creative tax lawyer with wide ranging experience
Simon’ s experience is wide ranging, having over 25 years experience in tax matters gained at major City firms. He advises a diverse mix of clients from financial institutions, funds, corporates and individuals on tax matters, often with an international element. In particular, Simon has a wealth of experience in the corporate, banking, funds, transportation, media and private wealth sectors. Simon also advises on tax controversy matters.
Simon started his tax career in 1990 as a solicitor in the corporate tax team at City firm Wilde Sapte and went on to become a partner (now Dentons) before leaving to head up the tax team at DLA Piper and more recently as a partner and consultant at Reed Smith. Over his career Simon has advised clients both internationally and domestically on both corporate tax planning and personal tax planning matters across many industries. He has particular interests in the transportation and media sectors and the finance and funds spheres.
Simon has also led a number of tax enquiry matters and has successfully defended tax cases in the higher courts. The international element of his work has taken him all over the world – from Japan to the Caribbean – and clients have included major corporations, high net worth individuals and governments. But Simon also values working with smaller companies and start-ups to help them grow a coherent tax strategy from the word go and has worked on venture capital and fund structures for growing businesses – such as video games companies and film producers.
Simon’s recent experience includes:
- Advising a syndicate of international banks and financial institutions on the tax aspects of a complex and innovative restructuring of a vessel facility, including the creation of separate ownership structures for the vessels (a warehousing loan structure and a direct equity loan structure).
- Advising various shipowners in respect of UK tax consequences of finance leasing.
- Advising shipowners in respect of UK Tonnage Tax.
- Advising on the VAT consequences of the acquisition/disposal of superyachts.
- Advising a shipowners association on the UK tax consequences of restructuring.
- Advising a major games development company on the efficient structuring and implementation of a strategy to maximise the availability of the UK Video Games Tax Credit.
- Advising a UK production company on 2 films and a TV series in relation to the utilisation of Spanish tax credits.
- Advising numerous financiers (banks, private partnerships, individuals), film producers (including US studios) and advisers on tax aspects of film, TV and games financings.
- Advising a major bank on a review of its loan book across numerous investors for financing capital subscriptions to partnerships.
- Advising Morgan Stanley on the tax aspects of the disposal of its European power, gas and emissions business.
- Advising a tax advisory firm on the tax aspects of a partnership investment strategy for UK limited companies.
- Advising non-domiciled individuals on an HMRC investigation under its Code of Practice 9 (fraud) into their tax residence status.
- Advising individuals on tax efficient investments, including HMRC investigations and litigation.
- Advising individuals on inheritance tax and capital gains tax consequences of business interests/disposals.
- Advising a charity on the tax consequences of setting up a UK branch.
- Advising an asset management company on the tax aspects of a proposed investment strategy for small UK occupational pension schemes.
- Advising non-domiciled individuals on inheritance tax planning.
- Advising a major bank on the tax aspects of a multi-million pound financing for the acquisition of a shopping centre.
- Advising a major property group on an HMRC tax investigation into the efficacy of SDLT planning.
Identified in Chambers as a key individual with “high praise from the market for his creativity and knowledge.”
Recommended in PLC “Which lawyer?” and in Best Lawyers (a US publication).
Insights and Publications
Upper Tribunal Decision in Samarkand and Proteus (UK film tax litigation)