Stephen Morse

07590 351 937 stephan.morse@pwc.com

Work Department

Tax disputes.

Position

Stephen is a barrister specialising in tax litigation and dispute resolution, with over 20 years’ experience of litigation and dispute resolution across VAT and indirect taxes, and now with a growing practice across direct tax, transfer pricing and personal taxes. He has worked across all industry sectors, and has particular experience in financial services, manufacturing, oil and gas, energy, media, travel and pensions.

Recent experience:

• continuing representation of Standard Chartered Bank in the Court of Appeal and in Supreme Court applications in the complex multi-party litigation concerning VAT grouping and the entitlement to historic VAT refunds going back to 1973
• successfully resolution of over fifteen individual cases through ADR
• recently settlement of a major transfer pricing dispute on behalf of a global bank

Stephen specialises in issues relating to international businesses, including resolving complex cross-border disputes, with other EU countries such as Ireland, Germany, France and the Netherlands. He has recently been instructed by a major bank in relation to a dispute concerning the UK’s Senior Accounting Officer regime. He is jointly responsible for PwC UK’s state aid practice. Stephen’s clients range from global banks and MNCs through to UK listed companies, private companies and individuals.

Notable cases:

• Lloyds Banking Group Plc (and others) v HMRC [2019] EWCA Civ 485
• Standard Chartered Bank v HMRC [2016] UKUT 434 (TCC)
• Standard Chartered Bank v HMRC [2014] UKFTT 316 (TC)
• Barclays Bank Plc v HMRC [2005] UKVAT V19302
• Xansa Barclaycard Partnership Ltd v Customs and Excise [2004] UKVAT V18780