Henry Bennett-Gough

Henry is a Barrister and Senior Manager with significant experience of all stages of tax disputes from HMRC enquiry through to litigation. Henry's practice is evenly balanced between dispute resolution prior to litigation with tax authorities and litigation in the tax tribunals and the High Court.

Much of Henry's work involves cross-border or international elements often requiring negotiations or disputes to be conducted in multiple jurisdictions at once and often involves the interplay between domestic litigation and negotiations between tax authorities. A recent example includes making applications for tax treaty resolution (and associated domestic litigation) on behalf of a multinational conglomerate in a dispute regarding their global trademarks programme which concerns the UK, US and French tax authorities. The dispute concerns in excess of ÂŁ320million of royalty payments across 30 entities and multiple years. The case involved coordinating the client's dispute across three jurisdictions simultaneously.

Henry also has significant experience litigating tax disputes in the High Court, Court of Appeal, Court of Justice of the European Union and the Tax Tribunal; he currently acts on the Stamp Taxes GLO which is awaiting hearing before the Court of Appeal. The case concerns the recovery of stamp taxes charged contrary to EU law. In this litigation PwC is the lead solicitor in relation to the group litigation on behalf of a number of well-known listed entities.

Prior to joining PwC, Henry worked in the Solicitor's Office of HMRC and conducted a number of significant cases in relation to personal tax and national insurance including Moorthy v HMRC and Big Bad Woolff v HMRC. Henry continues to act in respect of employment tax disputes, a recent highlight includes acting on behalf of 7 offshore oil and gas companies in respect of a challenge from HMRC in relation to their offshore manning arrangements on North Sea Oil rigs. These cases are worth a significant amount of tax and in some cases involve duty going back 20 years.