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Steven Porter

He's a wonderful talent. He's an expert in the field who is pragmatic and good to work with. (Chambers, 2023)

Partner, Global Investigations
Manchester, UK

Expertise

Steven is the Head of Addleshaw Goddard’s Tax Disputes and Investigations practice. With over 15 years of experience, he advises both large corporates and high-net-worth individuals on a wide range of tax disputes and investigations. Steven has extensive expertise in handling all forms of HMRC interventions, from routine enquiries to specialist fraud investigations. His practice is centred on resolving disputes efficiently, ensuring that most matters are settled without the need for a tribunal or courtroom.

When litigation becomes necessary, Steven is highly experienced in managing complex, high-profile disputes. He has particular expertise in advising on HMRC powers, including their application in investigations and enforcement actions. His deep understanding of HMRC’s approach allows him to provide strategic advice tailored to his clients’ needs.

Steven’s track record includes successfully managing group litigation before the Tax Tribunal, handling referrals to the Court of Justice of the European Union (CJEU), pursuing appeals to the Supreme Court, and conducting complex Judicial Review challenges. His ability to navigate these intricate processes ensures a comprehensive and effective approach to resolving even the most challenging tax disputes.

Steven’s combination of technical expertise, strategic insight, and extensive experience makes him a trusted adviser for clients facing contentious tax issues, whether they involve domestic or cross-border matters.

Experience

Steven’s Recent Experience Includes:

IR35 Investigations: Lead solicitor on five IR35 investigations involving multinational large businesses in the Oil & Gas and Retail sectors. Beyond addressing disclosure and rectification of errors, Steven provided strategic advice on restructuring off-payroll workforces to effectively manage IR35 tax risks and ensure compliance with regulatory requirements.
Dalriada Pensions Trustees v HMRC [2023] UKFTT 314 (TC): Represented Dalriada Pensions Trustees following their appointment by The Pensions Regulator. The case examined the tax implications of transactions implemented by the previous trustees. Six registered occupational pension schemes, collectively known as the Ark Schemes, operated a “pensions reciprocation plan” (PRP), designed to provide members with early access to pension capital without triggering unauthorised payment charges.
Corporate Criminal Offence (CCO) Investigation: Supported a multinational construction company during an investigation into the Corporate Criminal Offence of failing to prevent the facilitation of tax evasion. The team conducted a detailed review of the company’s records to identify root causes of errors related to employment status and VAT compliance. The team assisted in preparing a comprehensive disclosure to HMRC and provided guidance on improving internal processes and controls to mitigate future risks and ensure compliance with CCO requirements.
Code of Practice 8 (COP8) Enquiry: Assisted a large business in navigating multiple HMRC investigations, including a significant internal review prompted by a COP8 enquiry. The investigation centred on payments made to third parties connected to individuals with public profiles, with HMRC alleging these payments could constitute employment income or fall within disguised remuneration legislation. Steven conducted an analysis of the organisation’s records to address these complex allegations.
UK Residency Enquiries: Successfully advised a number of High-Net-Worth Individuals (HNWIs) on HMRC enquiries into their UK residency status, ensuring compliance and resolving disputes effectively.
Worldwide and Contractual Disclosure Facilities: Advised a range of HNWIs on disclosures to HMRC under the Worldwide Disclosure Facility and the Contractual Disclosure Facility. Recent work includes acting for a HNWI facing criminal prosecution for tax evasion. Steven’s intervention convinced HMRC to engage civilly, despite the absence of formal COP9 protections.

Education

University of Bristol, BSc (Hons) Biochemistry (1999-2002)
University of the West of England, Bristol Diploma in Law PGDL (2004-2005)
Northumbria University, Legal Practice Couse (2005-2006)

Publications

Author of Lexis’ “Penalties for offshore tax non-compliance”
He also writes regularly for Taxation Magazine and the Tax Journal.
Steven is regularly quoted in the broad sheets, including the Financial Times, The Times, the Telegraph and many other publications.

Recognition

Steven was featured in the Tax Journal’s “One minute with…” feature in March 2024

Testimonials

He’s very commercial and easy to deal with (Chambers 2023).
Steven is a very intellectually driven lawyer with a fantastic grasp of the pragmatic benefits to the client (Chambers and Partners 2025)
‘Fantastic legal mind and grasp of subject matter” (Legal 500, 2025)
Steven Porter always seems to be one step ahead. (Legal 500, 2025)

Professional Memberships