Rupert Shiers

Rupert Shiers

Partner
London

Email rupert.shiers@​hoganlovells.com

Phone +44 20 7296 2966

Fax +44 20 7296 2001

LanguagesEnglish

Practice groupCorporate & Finance

Sources praise Rupert Shiers as "hugely experienced" and "great to work with, practical and hands-on."

Chambers 2020, Contentious Tax, Band 1

For twenty years, Rupert has navigated complex HMRC discussions and tax litigation across all UK taxes. He works cross-sector and is the leader of our Tax Disputes team in the UK and Europe.

Rupert also provides technical knowledge in areas many group tax functions have not needed to develop themselves: taxpayer rights and HMRC powers, tax statutory interpretation, tax public law, tax-related evidence and procedure. His commercial approach has made him a valuable extension to in-house tax teams on a wide range of projects.

As well as giving astute advice on disputes in tax, Rupert handles tax issues in commercial disputes and leads tax-based internal investigations.

Rupert has worked full-time in HMRC disputes since before it became a real legal discipline, and has been identified for many years as a leader in his field. His style is always to work practically and collaboratively with HMRC when he can, but to be equally firm and direct. He worked for many years with ex-HMRC officers and chartered tax advisers in a Big 4 environment before returning in 2011 to practice in an international law firm.

Awards and recognitions

2018-2020

Acritas Star
Acritas Stars Independently Rated Lawyers

2020

Band 1, Contentious Tax
Chambers UK

2020

Leading Individual, Tax litigation and investigations
Legal 500

Education and admissions

Education

Bachelor of Civil Law (First), University of Oxford, 1996

MA, Law (First), University of Cambridge, 1994

CEDR, Accredited Mediator

Memberships

Chartered Institute of Tax, Management of Taxes committee

Confédération Fiscale Européene, ECJ task force, UK delegate

Representative experience

Philips Electronics in litigation to the Upper Tribunal and European Court of Justice, successfully defending £100m of tax losses

Aimia (the Nectar loyalty scheme) on their ground-breaking VAT dispute on multi-party supplies, based on their Supreme Court victory

 

eBay in a transfer pricing and diverted profits tax investigation by HMRC relating to £1bn of annual UK-related turnover

Eynsham Cricket Club (pro bono) in VAT litigation to the Court of Appeal, seeking charitable reliefs for a “CASC” sports club

 

Ensco plc and other oil rig owners in litigation to challenge tax legislation overriding the arm’s length principle, with US$1bn of tax at stake

 

An extensive HMRC investigation as to the “insurance intermediation” VAT exemption, for a tech-led company in a regulated UK group

 

A tax-technical whistleblowing investigation for a global bank relating to GBP multi-billion structured finance transactions

 

Pfizer in the First-tier Tribunal and European Court of Justice, overturning a Commission customs classification Regulation

A financial institution that had been defrauded, on an HMRC enquiry, defending US$200m tax losses, eliminating employment tax on bonuses

 

The executor of a US$1bn estate on HMRC investigations into tax residence and the effectiveness of offshore tax planning structures

FTSE 100, FTSE 250, and privately-owned entities on HMRC “wholly and exclusively” corporation tax enquiries, for tax of over £100m

 

Ball Group in corporation tax litigation to the Upper Tribunal, on complex accountancy issues and the Tribunal’s approach to them

 

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