Hogan Lovells 2024 Election Impact and Congressional Outlook Report
Rupert Shiers
Partner Corporate & Finance
Languages
English
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Overview
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Experience
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Credentials
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Insights and events
Chambers 2020, Contentious Tax, Band 1Sources praise Rupert Shiers as "hugely experienced" and "great to work with, practical and hands-on."
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.
Chambers 2020, Contentious Tax, Band 1Sources praise Rupert Shiers as "hugely experienced" and "great to work with, practical and hands-on."
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
Credentials
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