Peter Johnson

Tax lawyer specialising in direct tax

Peter focuses on helping clients resolve direct tax disputes with HMRC. He also advises international businesses on tax issues impacting them.

Peter has particular experience resolving disputes involving international corporate tax matters and financing, and also frequently acts in tax disputes involving multidisciplinary aspects - encompassing tax law, accounting, EU law, commercial, equity and administrative law issues.

Where litigation proves necessary, Peter has acted in cases appealed to the Tax Tribunal, High Court (Business & Property Courts), High Court (Administrative Court), Court of Appeal and the Court of Justice of the European Union. Peter’s recent litigation experience includes litigating, and advising in the settlement of a dispute related to a holding and financing structure in the financial services part of an international business which was reported to be worth $1bn in tax, raising issues covering the unallowable purpose rule, anti-arbitrage, the law of misrepresentation and limitation periods.

"Successful resolutions of tax disputes tend to involve three key ingredients: (i) putting forward a strongly-evidenced position; (ii) seeing things from the tax authorities’ perspective, and (iii) being agile to find the best way forward in the case in hand."

Peter’s legal practice is complemented by the experience obtained earlier in his career advising on and implementing several complex high-value international reorganisations and financing transactions, and his continued experience advising certain large international clients of the firm on a wide range of UK corporation tax issues.

Peter joined PwC in 2007 from Cambridge University. Peter is a member of the Chartered Institute of Taxation Technical Committee (Management of Taxes). Peter also acts as a career coach to a number of accountants and lawyers in PwC’s London tax practice.