Stuart Pibworth

Associate London

Biography

Stuart Pibworth
Stuart Pibworth is an associate in the London Tax team. He advises clients on a broad range of complex UK and international tax matters, including in the context of corporate and private equity transactions, business restructurings, insolvencies, distressed situations, finance matters, and tax litigation.

Prior to joining Weil, Stuart was an associate in the tax team at a leading international law firm where he advised clients on a wide range of tax matters including international cross-border reorganisations, UK asset management arrangements, cross-border corporate acquisitions and finance transactions. He also advised clients dealing directly with the UK tax authority, particularly in relation to advance pricing agreements and transfer pricing matters.

Stuart is also a Chartered Tax Adviser and recipient of the John Wood Medal from the Chartered Institute of Taxation.

Stuart has written numerous articles for leading publications including British Tax Review, Tolley’s Tax Digest, Tax Journal, Taxation, Tax Adviser, International Tax Review, LexisNexis and PLC.

Representative experience includes advising:

  • Westinghouse Electric Company on the global and European aspects of its chapter 11
  • Ambac UK in relation to the restructuring of Ballantyne Re plc
  • Advising key noteholders on the restructuring of Abengoa’s cross-border facilities
  • Advising Edcon Group in relation to the tax aspects of its restructuring
  • Willis Towers Watson PLC in its pending $80 billion combination with Aon PLC
  • Sun Life Financial Inc. in relation to the merger of Sun Life-owned Bentall Kennedy and Tetragon's GreenOak to create a $47bn global real estate platform
  • VINCI on the acquisition of Gatwick Airport
  • Public Sector Pension Investment Board, along with BC Partners, in the acquisition of Keter Plastic
  • The Government Investment Corporation of Singapore fund, in relation to various matters, including involvement in extensive negotiations with HMRC to access sovereign immunity from UK taxation for the fund in respect of real estate investments made in the UK

Firm News & Announcements, Speaking Engagements, Guides and Resources, Latest Thinking, Awards and Recognition

Firm News & Announcements

Latest Thinking

  • Coronavirus: Tax on Measures to Tackle Cash Management Blog Post — Tax Blog — By Jenny Doak and Stuart Pibworth — June 08, 2020

    Businesses are facing unprecedented levels of operational disruption with new challenges emerging daily. One of the key challenges is cash management and liquidity, but an important question is how we factor taxes into this. When considering the various measures introduced, some key tax considerations have emerged. Key points Basic principles of the coronavirus job retention

    The post Coronavirus: Tax on Measures to Tackle Cash Management appeared first on Weil Tax BLOG.

    ...
  • Guarantees Revisited Blog Post — Tax Blog — By Jenny Doak and Stuart Pibworth — May 20, 2020

    Although guarantees are common, the tax treatment of guarantee arrangements can be complex. However, before jumping to the tax analysis, it is first important to understand the nature of the guarantee arrangements and their legal effect. Once the legal nature of the various guarantee relationships are understood, the tax analysis can be applied. However, even

    The post Guarantees Revisited appeared first on Weil Tax BLOG.

    ...
  • COVID-19 Impact on Corporate Tax Residence and Substance: Investment Funds and Multinationals Blog Post — Tax Blog — By Aron Joy, Jenny Doak, Oliver Walker and Stuart Pibworth — March 31, 2020
    Snapshot Travel restrictions and social distancing measures imposed as a result of the crisis mean that non-UK companies are at risk of becoming tax resident in the UK or breaching substance requirements if board meetings are held or decisions taken without careful forethought. This could have long term consequences.  Similar issues were encountered, albeit on […] ...
  • Brexit and Tax: An Uncertain Future Blog Post — Tax Blog — By Jenny Doak, Oliver Walker, Stuart Pibworth and Akash Mehta — February 03, 2020
    The consequences of Brexit on UK tax: key tax implications of Brexit for businesses. The UK has a relatively business-friendly tax regime, which should be largely unaffected by Brexit, and we can expect the current government to plug any “gaps” created by Brexit to ensure the UK remains competitive. Since the 2016 vote, the government has emphasised that the UK is “open for business” and will make the most of the opportunities created by Brexit. ...
  • Withholding Tax: HMRC’s Revised Approach to Late Payment Interest on Intra-EU Interest and Royalties Payments Blog Post — Tax Blog — By Stuart Pibworth — January 28, 2020
    Recently HMRC has updated its published guidance to reflect its new policy not to impose late payment interest in respect of intra-EU payments of interest and royalties where those payments are made gross notwithstanding that treaty clearance to make gross payments has not been obtained at the time of making the payment. The new policy follows a 2018 decision of the Court of Justice of the European Union in which it was held that Bulgarian law was incompatible with the EU fundamental freedom to provide services. HMRC’s view is that, following the 2018 Decision, it is precluded under EU law from imposing late payment interest in respect of intra-EU payments of interest or royalties to the extent that application of the relevant DTT would result in no, or a reduced rate of, tax being required to be withheld from the payment. ...

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