Patrick Cannon advises on and represents clients in appeals to the tax tribunals involving business and corporation tax including:

  • Restructuring, reorganisations and demergers
  • Acquisitions and mergers
  • Private equity investment
  • Joint venture structuring
  • UK inward investment including business investment relief
  • Enterprise investment schemes
  • Enterprise management incentive schemes or EMI and VCT, performance share plans, unapproved options
  • Protected cell companies and captive insurance companies
  • Property tax including SDLT and VAT

If you need to choose an expert among corporation tax barristers or business tax barristers then Patrick Cannon can certainly help if you are considering any of the above or if you are facing an HMRC tax investigation or appeal in any of these areas.

Contact Patrick Cannon to see if he can assist you.

Areas of tax expertise

Patrick Cannon can help with advice and tax tribunal representation in the following matters.

Losses and capital allowances

  • The correct computation of the trading profit or loss of a limited company for its financial year
  • Computation and inclusion of any capital allowances (which increase the loss) and any balancing charges (which reduce the loss)
  • Carry back of losses to earlier accounting periods or carry forward for offset against the profit of future periods.


  • Computation of partnership profits and losses and their allocation to partners
  • Partnerships, including limited liability partnerships (LLPs), are normally transparent for tax purposes but not always so
  • Partnership tax anti-avoidance legislation that can prevent partnerships being used for tax avoidance for example rules that re-attribute profits in ‘mixed-member’ partnerships and rules governing ‘salaried members’ applying to LLPs
  • Computation of partnership chargeable gains

Employee Remuneration

  • Employee benefit trusts
  • Owner managers remuneration strategy
  • Tax-efficient profit extraction
  • Employee share and share option awards
  • Issues with employee share ownership schemes and tax clearances and HMRC tax reporting requirements
  • Application of construction industry tax deduction scheme rules
  • Tax advice on redundancies, retirement and termination payments
  • IR 35 and employment and self-employment status
  • Assistance with HMRC enquiries and investigations

Tax Avoidance Issues

  • Reviewing tax avoidance schemes and arrangements
  • Representation in HMRC tax avoidance enquiries and investigations, settlement and withdrawal arrangements
  • Advice on HMRC powers including HMRC time limits and discovery and information powers
  • Accelerated Payment Notices and Follower Notices and penalties appeals
  • COP 9 investigations and criminal tax investigations

Patrick Cannon can advise and represent you with HMRC and in the tax tribunals in all the above situations plus in private client matters, VAT, and Stamp Duty Land Tax.

How to hire Patrick Cannon

Patrick is allowed by the Bar Standards Board to accept instructions directly from private clients under public access without going through a solicitor and he is also permitted to conduct litigation which means that he can issue legal proceedings on your behalf, deal with applications, witness statements and serve documents and correspond with HMRC and other third parties directly.

Get in touch here with Patrick to discuss your situation and how he might assist you.

Get In Touch

For professional and insurance reasons Patrick is unable to offer any advice until he has been formally instructed.