Mark Whitehouse

Mark leads the Direct Tax Legal Disputes team and has been involved in contentious tax work for 28 years.

Mark leads PwC’s Legal Tax Disputes team and has been dealing with contentious tax issues for companies for over 28 years. He is a solicitor and qualified at a magic circle firm before spending some time at HMRC Solicitor’s Office. Mark litigated the UK’s only substantive transfer pricing case (DSG Retail), has taken cases to the European Court, dealt with judicial review challenges and most recently represented GE in relation to challenges in the High Court and Court of Appeal.

“Lengthy tax disputes can be extremely disruptive to business. Reaching resolution requires a real focus on the facts and an understanding of HMRC’s rigorous governance processes”

Much of Mark’s work however never gets to Court and is resolved in the course of enquiries. He often advises on transfer pricing enquiries, diverted profits tax, unallowable purpose and other targeted anti-avoidance rules. He has a particular expertise in international issues and has dealt with tax treaty arbitration, mutual agreement procedures and multilateral audits. He is a member of PwC’s international tax disputes network.

“The best way to avoid a dispute is to address it proactively and anticipate the challenges.”

Mark is keen to explore alternative ways to resolve disputes and is an accredited mediator. He frequently works on projects involving HMRC’s alternative dispute resolution process.