Gideon Sanitt Partner

Partner

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Gideon specialises in tax litigation but has a background in transactional tax work. His tax litigation work has given him experience at all levels of the UK Courts and the European Courts.

Gideon has worked on disputes and investigations involving complex corporate and financial transactions for a variety of multinational and FTSE listed companies across both direct and indirect tax, as well as dealing with investigations involving high-net-worth individuals.

Gideon also has significant experience in high value regulatory investigations as they relate to tax issues.

Gideon takes a particular interest not just in advising on disputes but in managing the risks of transactions, so that the extent of any such dispute is minimised, and in seeking solutions outside of the Courts, whether through well-run compliance or effective settlements.

With a transactional background covering, in particular, M&A and finance, as well as matters with a significant international dimension, Gideon also has experience of how some of the most complex tax rules apply in practice. Such expertise is invaluable in managing the risks of those transactions, advising on any disputes that may arise and finding the most effective solutions.

Expertise

Recent work

A FTSE 100 company

Advising a FTSE 100 company in relation to a group litigation order involving approximately 300 claimants with respect to the VAT treatment of certain supplies and their compliance with EU law.

Investment managers

Advising various firms on a number of claims being brought by HMRC in relation to the taxation of management fees, the application of the salaried member rules and the taxation of remuneration arrangements.

A foreign multinational

Challenging a claim by a tax authority in Africa that a foreign multinational was trading in that country through a permanent establishment, including challenging the transfer pricing position if that were the case.

Residence

Successfully defending an individual against a claim by HMRC that he was resident for tax purposes in the UK.

Domicile

Advising a number of high-net-worth individuals in relation to their domicile status, including bringing an appeal before the Tax Tribunal.

A high profile individual

Bringing a judicial review and High Court challenge in relation to the attempted rescission by HMRC of a long-running and substantial settlement with a high profile individual.

Clearance application

Applying for judicial review in relation to a VAT clearance obtained by a multinational business.

Enterprise zones

Bringing a judicial review challenge and appeal to the Tax Tribunal with respect to HMRC’s approach to the taxation of certain Enterprise Zone arrangements.

Film financing arrangements

Acting for advisors in respect of claims by multiple investors concerning various film financing arrangements.

Corporate criminal offence

Advising a number of corporates and partnerships with respect to putting in place procedures as required by the rules concerning the failure to prevent the facilitation of tax evasion offence.

HMRC criminal investigation

Acting for a senior executive in relation to proceedings in which HMRC asserted fraud.

Regulatory investigations

Acting for financial institutions in relation to complex, cross-border transactions that were the subject of regulatory investigations.

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What people are saying

"Gideon Sanitt has an impressive ability to create a clear picture from a complex factual and technical position. He comes across as very knowledgeable, with a wealth of relevant experience of disputes with HMRC to draw on."

The UK Legal 500 2024

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