Illustrative assignments

The consultancy services provided by Marcus Stanton cover both UK and international matters, typically those involving banks, quasi banks, private equity firms, multinational corporations, individuals, partnerships, trusts and special purpose vehicles.

Illustrative case work has included:

• forensic investigation of multi legged financing structures, in particular cross border structures
• intercompany pricing structures
• off balance sheet financing structures
• the use of financial derivatives, including interest rate swaps, currency swaps and various option products
• the use of trusts and special purpose vehicles
• tax driven structures used by banks, companies and high net worth individuals, including film finance partnerships
• hybrid funding vehicles.

Expert evidence has been given in various Courts and Tribunals, with illustrative cases including in the High Court in London (Mahonia and JP Morgan v West LB, 2003), the High Court in Wellington, New Zealand (BNZ v the Commissioner of Inland Revenue, 2009), the High Court in Auckland, New Zealand (Westpac Banking Corporation v the Commissioner of Inland Revenue, 2010), a UNCITRAL Tribunal in Lagos, Nigeria (Econet Wireless v Delta State Ministry of Finance Incorporated & Others, 2011), the High Court in Singapore (Various v Asia Pacific Breweries, 2008), the First Tier Tax Tribunal in London (Howard Schofield v Revenue and Customs, 2008); (Eclipse Film Partnership No 35 LLP v Revenue and Customs, 2011); BNP Paribas (London Branch) v Revenue and Customs, 2016), the Tax Appeals Commissioner (Ireland), (Redacted v Revenue Commissioners, 2017); (Redacted v Revenue Commissioners, 2019) and the First Tier Tax Tribunal in London, (BlueCrest Capital Management v Revenue and Customs, 2020).

Further litigation work has been undertaken in South Africa and Australia.