Darren
Oswick

Darren is a highly experienced tax partner and has broad ranging transactional, advisory and tax disputes expertise. He leads both the UK and international tax practices.

In recent years, his practice has been split between advisory and disputes work.

His advisory work focuses on clients in the Financial Institutions and Asset Management & Investment Funds sectors. He regularly advises clients in these sectors on a range of complex issues, including intra-group financing arrangements, investment fund structuring and the tax treatment of carried interest.

In his disputes work, he has appeared before the First-tier Tribunal, Upper Tribunal and Court of Appeal in numerous high value disputes, including the application of the transfer pricing and loan relationship unallowable purpose rules to intra-group financing arrangements, the application of the UK / Ireland double taxation treaty to UK interest withholding tax and the application of various aspects of the PAYE rules to employment-related securities options, as well as various procedural matters such as obtaining closure notices. He has also acted for clients in numerous HMRC investigations including in relation to the potential application of the unallowable purpose, salaried member and mixed member rules.

Darren became a partner in 2010. He is a member of the City of London Law Society Tax Law Committee.