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Patrick Cannon

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Patrick Cannon
LL.B, BCL (Oxon), CTA (Fellow)
Patrick Cannon in 2015 Patrick-cannon.jpg
Patrick Cannon in 2015
Born1958 (age 62–63)
🏳️ Nationality
🎓 Alma materDe La Salle College, Malvern; LSE; St John’s College, Oxford.University of Oxford
💼 Occupation
Barrister
Taxation advocacy, notably SDLT
Notable workTolley’s Stamp Taxes
🌐 Websitewww.patrickcannon.net

Patrick Cannon is a tax barrister in London specialising in the resolution of tax disputes[1][2]. He is the author of several Tolley’s tax guides and a recognised specialist in Stamp Duty advice and property taxes.[3][4]


Education and early career[edit]

He read law at the London School of Economics and St John’s College, Oxford before admission as a solicitor in 1984. He began to specialise in tax work and joined what is now PricewaterhouseCoopers, passed the exams for the Chartered Institute of Taxation.[5] and rose to become head of Stamp Duty at PwC.[6]

Barrister career[edit]

He was called to the Bar in 2003 [2][7] and is licensed by the Bar Standards Board to accept public access work and conduct litigation. He is a former council member of the Chartered Institute of Taxation and is based at Old Square Tax Chambers in Lincoln’s Inn, London.

Work[edit]

Patrick advises on and appears as a barrister in civil and criminal tax disputes with HMRC, challenges to tax avoidance schemes and action against the mis-selling of aggressive tax avoidance schemes now subject to APNs and Follower Notices.[3][7].

He has developed a specialism in Stamp Duty Land Tax cases[8] and has appeared as a speaker concerning SDLT matters[9], including use of the Human Rights Act in UK tax cases.[10]

He is the author of a series of professional reference works on the General Anti-Abuse Rule (GAAR), which was instated to enable HMRC to counteract tax advantages arising from “abusive” tax arrangements.[11]

In November 2017 Cannon acted for the taxpayer to quash search warrants issued by HMRC in a case concerning the tax consequences of employment structure. The judicial review concluded that "in applying for the warrants, HMRC misled the judge as to the law and as to the way in which the business model operated.".[12]

Controversy[edit]

In 2003 Cannon, as spokesperson for PwC, was quoted in the Sunday Telegraph stating that the Treasury was “actively planning taxing the sale of first homes”.[13] The claim drew fierce rebuttal from HMRC who accused Cannon of fabricating "irresponsible nonsense". PwC later retracted the claim and asserted that the Telegraph's reporting of Cannon's statement was incorrect.[14][15].

Publications[edit]

Books
  • Author of Tolley's Stamp Taxes[16][17][18][19][20][21] and Tolley's Disclosure of Tax and VAT Avoidance Schemes.[2]
  • Editor of Tolley's Property Taxation[22][23]
  • GAAR: A Practical Approach (Key Haven, Aug 2013)[11]
Articles
  • "Chancellor will struggle to tax overseas homeowners", Property Week, November 2013[24]
  • "Project Blue - The Fog Clears", Tax Journal, June 2016[25]
  • "Keeping It Quiet" Taxation, October 2014[26]

References[edit]

  1. "Old Street Tax Chambers". Retrieved 14 December 2018.
  2. 2.0 2.1 2.2 "Lexisweb". Retrieved 14 Dec 2018.
  3. 3.0 3.1 "Simon Farrell, QC". Retrieved 18 Dec 2018.
  4. "Chambers of James Kessler, QC". Retrieved 3 January 2019.
  5. "Simply Law Jobs: Advice from an experienced tax barrister". Retrieved 18 Dec 2018.
  6. Watts, Robert (22 October 2003). "Stamping down on duty dodgers". Daily Telegraph. Retrieved 7 January 2019.
  7. 7.0 7.1 "Direct Access Portal: Patrick Cannon". Retrieved 15 Dec 2018.
  8. Houlder, Vanessa (1 November 2012). "Revenue steps up battle on tax dodgers". Financial Times. Retrieved 19 December 2018.
  9. "Stamp Duty Land Tax: Speakers". Retrieved 18 Dec 2018.
  10. "Lexis Webinars: Speakers – Patrick Cannon". Retrieved 18 Dec 2018.
  11. 11.0 11.1 "The GAAR: Third Edition". Retrieved 18 Dec 2018.
  12. "Hart & others vs. HMRC - Judicial Review" (PDF). Retrieved 7 Jan 2019.
  13. Watts, Robert; Elliott, Francis (19 October 2003). "Chancellor looks at 40 per cent tax on all home sales". Sunday Telegraph. Retrieved 7 January 2003.
  14. Morris, Nigel (20 October 2003). "House sale tax claims are 'unadulterated garbage', says Treasury". The Independent. Retrieved 7 January 2019.
  15. "Fury over 40% house sales tax". 20 October 2003. Retrieved 7 January 2019.
  16. "Tolley's Stamp Taxes 2003-04". Retrieved 19 Dec 2018.
  17. "Tolley's Stamp Taxes 2005-06". Retrieved 19 Dec 2018.
  18. "Tolley's Stamp Taxes 2010-11". Retrieved 19 Dec 2018.
  19. "Tolley's Stamp Taxes 2012-13". Retrieved 18 Dec 2018.
  20. "Tolley's Stamp Taxes 2017-18". Retrieved 18 Dec 2018.
  21. "Tolley's Stamp Taxes 2018-19". Retrieved 18 Dec 2018.
  22. "Tolleys Property Taxes 2012-13". Retrieved 19 Dec 2018.
  23. "Tolleys Property Taxes 2018-19". Retrieved 19 Dec 2018.
  24. Cannon, Patrick (22 November 2013). "Chancellor will struggle to tax overseas homeowners" (PDF). Property Week. Retrieved 19 Dec 2018.
  25. Cannon, Patrick (9 June 2016). "Project Blue: the fog clears". Tax Journal. Retrieved 19 December 2018.
  26. Cannon, Patrick (18 October 2018). "Keeping It Quiet" (PDF). Taxation: 12–14. Retrieved 19 December 2018.

External links[edit]


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