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Of Counsel

Thomas Reyes

Tax, structuring and revenue disputes

Biography

Thomas Reyes joined the firm as Of Counsel in 2019 after twenty-two years in tax practice, including eleven leading the tax group of a national firm. He is both a lawyer and a chartered accountant, which is why he tends to be brought in before a transaction is structured rather than after it is questioned.

His advisory work covers direct and indirect tax across corporate transactions, cross-border arrangements, group reorganisations, holding structures and investment vehicles, together with the contemporaneous documentation that supports the position taken.

On the contentious side Thomas handles audits, assessments and reassessments, and appears before tax tribunals and appellate authorities. He has a particular focus on transfer pricing, where the defence depends almost entirely on documentation prepared years earlier.

Thomas mentors the firm's junior lawyers on the tax dimension of corporate work, on the principle that a corporate associate who cannot spot a tax issue will eventually create one.

Education & qualifications

  • LL.M., Taxation
  • Chartered Accountant
  • LL.B.
  • Admitted to the Bar, 1997

Professional experience

  1. 2019 – Present

    Of Counsel, Regulatory & Advisory

    Tax structuring, transfer pricing and revenue disputes.

  2. 2008 – 2019

    Head of Tax, national practice

    Led a fourteen-lawyer tax group across advisory and contentious work.

  3. 1997 – 2008

    Tax counsel and chartered accountant

    Corporate tax advisory, audit defence and appellate representation.

Notable achievements

  • Represented clients in over 400 audits, assessments and tax appeals
  • Advised on the tax structuring of transactions exceeding $1.2bn in aggregate value
  • Successfully defended transfer-pricing positions in multiple contested assessments
  • Former member of a national committee on tax administration reform

Publications

  • "Transfer Pricing Documentation: Building the File Before You Need It" — Tax Review
  • "Holding Structures and Substance Requirements" — annual tax conference paper

Memberships

  • International Fiscal Association
  • Institute of Chartered Accountants — Fellow
  • Bar Council — Taxation Committee
Consultation

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Response time
Every enquiry acknowledged within one business day.