Gareth Banfield
Counsel
London
Gareth Banfield
Counsel
London
Contact details
Gareth has a very broad practice and advises on all aspects of corporate tax and VAT. His experience includes advising on the tax aspects of complex domestic and international financing transactions including bank and project finance, capital markets transactions, securitisations, derivatives and structured finance transactions as well as advising on tax issues on corporate transactions including mergers, acquisitions and joint ventures, corporate restructurings and reorganisations and private equity transactions. He also advises on tax disputes and investigations and has experience assisting companies through HMRC’s high risk corporates programme and in litigating tax matters.
Qualifications
Professional
Academic
Related articles
Publications: 24 July 2023
Podcast: Pillar Two and M&A – How the new global minimum rate of tax is impacting M&A
In this podcast, our tax experts explore some practical implications that Pillar Two could have on M&A transactions and documentation.
Qualifications
Professional
Academic
Experience highlights
Advising a major banking group on the tax consequences of the ring-fencing of its UK retail banking operations, pursuant to the Financial Services (Banking Reform) Act 2013 including setting up operational service companies to serve both the ring-fenced bank and non-ring fenced banks.
Successful VAT litigation: Successfully litigating a VAT case before the First Tier Tribunal for a financial institution.
Advising a major banking group on the tax consequences of the structuring and implementation of the recapitalisation plan for the Bank which involves a consensual bail in of subordinated debt (the first of its kind in the UK) and a highly structured capital contribution of GBP450m from the Group to the Bank, involving a debt/equity conversion effecting a change of control of the Bank and implementation of inter-conditional liability management exercises by way of exchange offers and an English scheme of arrangement.
Advising a major UK company on settlement discussions with HMRC as part of their High Risk Corporates Programme in relation to certain financing arrangements with an amount of tax at stake in excess of GBP100m.
Other noteworthy experience
Advising:
- Advising a number of financial institutions on VAT issues arising in connection with pension fund management.
- Advising financial institutions on the VAT treatment of certain payment services.
- Advising a leading global investment adviser in relation to certain VAT litigation issues.
- The lenders to a participant in the unincorporated joint venture developing the London Array project.
- A global insurance company on the GBP12bn sale of a UK annuity portfolio to Rothesay Life.
- A division of a multinational financial institution on the tax consequences of the transfer of its EEA Investment banking business from the financial institution to the Dutch subsidiary of the financial institution.
- A UK financial institution on its strategic partnership with Schroders in the wealth, investment and financial planning sector.
- A multinational financial institution on the acquisition of the worldwide Equity Markets and Commodities activities of Commerzbank.
- A multinational insurance company on its GBP5.6bn acquisition of Friends Life.
- The banks on tax aspects of the GPB1.25bn restructuring of Drax, the largest coal fired power station in Western Europe.
- Eversholt Investment Group (EIG) on the acquisition of Eversholt Rail Group (Eversholt), one of the UK's three leading rail rolling stock companies, from HSBC Asset Finance (UK) Ltd. The transaction values Eversholt's gross assets at approximately GBP2.1bn.
- A sovereign wealth fund on its proposed establishment in the UK and related investment, regulatory and tax issues.
- Coca-Cola Iberian Partners on its three-way merger with the U.S. publicly listed bottling company Coca-Cola Enterprises Limited and the private German bottling company.
- Coca-Cola Erfrischungsgetränke, a wholly owned subsidiary of The Coca-Cola Corporation (Coca-Cola), to form a new UK company Coca-Cola European Partners.
- A major multi-national retailer on the restructuring of their equity holding structure and intra-group debt arrangements.
