Expertise

Sam is a Legal Director in Addleshaw Goddard’s Tax Disputes and Investigations practice, advising large corporate clients and high-net-worth individuals throughout the full spectrum of interactions with HMRC, from the outset to the resolution of their tax matters. He provides guidance to clients facing uncertainty in their tax affairs, whether relating to the application of law or the optimal approach to managing enquiries and investigations. Sam is skilled at anticipating and pre-empting disputes with HMRC, helping clients avoid costly litigation and identifying routes to favourable, cost-effective settlements.

When litigation is unavoidable, Sam has significant experience handling complex disputes on behalf of clients against both HMRC and third parties in commercial matters involving tax, such as SPA claims and VAT disputes. His in-depth knowledge of HMRC’s powers and limitations—including investigations, time limits, information gathering, and enforcement—ensures his clients are well-equipped to engage with HMRC strategically and efficiently. Sam’s extensive litigation experience covers appeals before the tax tribunals and judicial review proceedings in the Administrative Court. He advises clients, including large groups of litigants, through these processes with efficiency, even in the most complex cases.

Sam works across a broad range of taxes, including VAT, Corporation Tax, PAYE, and Income Tax, and is adept at quickly upskilling in even the most obscure areas of tax. He has particular expertise in capital allowances, environmental taxes (such as aggregates levy and landfill tax), and taxation in the financial services sector, including pensions. His experience spans most of AG’s sectors, including Financial Services, Energy, Utilities and Transport, and he has advised on numerous Nationally Significant Infrastructure Projects, giving him a strong understanding of the pressures and contractual arrangements involved in these types of developments.

Experience
  • VAT: Advising a number of client in relation to contentious or uncertain VAT treatments including in relation to the Financial Services exemptions, VAT in relation to prize draws, VAT on online subscriptions etc. Input ranging from advisory to appeals.
  • Capital Allowances: Nichols & French v HMRC (on-going tribunal appeal): Conducting a tribunal appeal on behalf of Mr Nichols and Mr French as representatives of syndicates of investors in 10 enterprise zone arrangements.
  • Landfill Tax: S Walsh & Son Ltd v HMRC (no decision): Represented S Walsh in a tribunal appeal against HMRC’s landfill tax assessment concerning silt/clay material from a wash-plant and its qualifying material status. In the face of a conclusive case against them, HMRC withdrew their assessment on day 3 of 4 of the hearing.
  • Offshore: Transfer of Assets Abroad and Offshore Anti-avoidance Advice: Advised a number of HNW individuals and Trustees in relation to their offshore asset holding including complex trust arrangements. Input varies from assistance with compliance, advice on structuring, handling HMRC investigations and enquiries, settlements and unwinding structures (including asset distribution and avoiding double taxation).
  • Unauthorised Payments: Dalriada Pensions Trustees v HMRC [2023] UKFTT 314 (TC): Represented Dalriada following their appointment by The Pensions Regulator to six registered occupational pension schemes operating a pension liberation arrangement. Dealing with complex unauthorised payments, calculations, tribunal appeal and resolution with HMRC;
  • Tax based Contract / SPA Disputes: Contract disputes over VAT implications associated with HMRC’s assessment of supplier of services, SPA disputes concerning unknown tax liabilities including over UK tax and tax in other jurisdictions.
Testimonials

“very experienced lawyer’

Legal 500, VAT and indirect tax (2024)