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© 2012 Dorsey & Whitney LLP

  • "First class" and "particularly attentive to the needs of his clients" Legal 500 (2009, 2011)
  • “An enormously experienced barrister with extensive European taxation expertise.” (Chambers UK Directory 2010 ed.)
  • Ranked for contentious tax by Chambers UK Directory 2010
  • Winner, "UK Tax Lawyer of the Year," Lexis Nexis 2006 Awards
  • Team ranked top for contentious tax (Chambers UK Directory 2008-2010)
  • Team ranked top for tax litigation: Legal 500 (2009)
  • His team has won many awards:
    • Winner "European Tax Litigation Firm of the Year", International Tax Review European Awards 2007 & 2009
    • Winner, "ECJ Award 2008", International Tax Review European Awards 2008
    • Winner, "Tax Team of the Year," Legal Business Awards 2006
    • Winner, "Editor's Award," International Tax Review European Awards 2006
    • Finalist, "Best Tax Team in a Law Firm”, Lexis Nexis Awards 2009, 2008
  • Member of the team ranked among "the best of the UK" for contentious tax, Chambers UK Directory 2008 ed.

  • University of Manchester (M. Phil, 1993)
  • University of Manchester (LL.B, 1977), with honors

  • England & Wales
  • Qualified barrister
  • Member of Lincoln’s Inn 
  • Chartered Accountant (England & Wales)

  • Spoken French and German (reading knowledge of Dutch, Italian and Spanish).

Paul Farmer

Partner
London
P: +44 (0)20 7826 4501
F: +44 (0)20 7588 0555
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Paul Farmer is a Barrister and Partner in Dorsey’s London Tax and Commercial Litigation group. He has wide-ranging experience of litigation in the United Kingdom courts (lower courts to the Supreme Court) and the European Court of Justice and has a broad background in European law and international tax law (including corporate tax, VAT and other indirect taxes). In addition to litigation his practice also includes advisory work and making representations to relevant EU bodies. Paul joined Dorsey in 2007 from his position as Head of Tax Policy Co-ordination at the European Commission. Previously he had been a practising barrister at Pump Court Tax Chambers and had held numerous posts at the European Commission and the European Court of Justice (including référendaire to Advocate General Sir Francis Jacobs). He is ranked by both Legal 500 and Chambers and described as “first class” and “particularly attentive to the needs of his clients”. In 2006 he was Lexis Nexis Tax Lawyer of the Year. A frequent author and speaker on EU law he co-authored the leading publication “EC Tax Law” with Richard Lyal of the Commission’s Legal Service. Paul's previously held posts include:

  • Visiting Professor, King’s College, London
  • International Research Fellow, SAID Business School, Oxford
  • Member of the ECJ task force of the European Fiscal Federation

Representative Work

Significant cases in which Paul has acted include:
  • Case C-465/03 Kretztechnik v Finanzamt Linz [2005] ECR I-4357 concerning the legality of the UK rules on VAT on share issues
  • Case 446/03 Marks & Spencer v Halsey [2005] ECR I- 10837 concerning the compatibility with EU law of the UK system of group relief
  • TNT Post v Commissioners for Her Majesty’s Revenue & Customs [2009] ECR I-3025 concerning judicial review of the Post Office’s VAT exemption
  • Autologic Holdings plc & others v Commissioners of Inland Revenue [2005] UKHL 54, [2006] 1 AC 118: concerning the jurisdiction in tax matters of the High Court
  • C-374/04 Test Claimants in the ACT Class 4 Group Litigation v Commissioners of HMRC [2006] ECR I-11673: claims challenging the failure to grant treaty credits in certain circumstances under the UK’s imputation system 
  • C-446/04 Test Claimants in the FII Group Litigation v Commissioners of HMRC [2006] ECR I-11753: claims challenging the UK system of dividend taxation and the incidence of surplus ACT upon UK groups with their sources of profit abroad
  • C-524/04 Test Claimants in the Thin Cap Group Litigation v Commissioners of HMRC [2007] ECR I-2107: claims challenging the lawfulness under European law of the UK’s thin capitalization provisions
  • C-201/05 Test Claimants in the CFC & Dividend Group Litigation v CIR [2008] ECR I-2875: claims challenging the lawfulness under European law of the UK’s controlled foreign company rules and aspects of their dividend taxation provisions
  • Europcar UK Ltd & ors v Commissioners of HMRC [2008] EWHC 1363 (Ch), [2008] STC 2751: considering whether a valid claim in mistake had been made prior to the coming into force of s320 FA04
  • MoneyGram Payments Systems v Commissioners for HMRC (Lon/2006/8084) concerning the UK and EU moneylaundering rules.

As referendaire to Advocate General Jacobs Paul worked on a wide range of cases covering virtually all areas of EU law, including free movement of goods, persons, services and capital, VAT, state aid, sex discrimination, intellectual property, environment, social security, competition, customs duties as well as general principles and remedies.

Professional Activities

  • Member, Revenue Bar Association
  • Member, Institute of Chartered Accountants (England & Wales) 
  • Visiting Faculty Member, International Tax Centre, University of Leiden (Netherlands)

Attorney Articles

September 16, 2010
European Limitations on Attorney-Client Privilege for Inside Counsel – Akzo Nobel Chemicals & Akcros Chemicals – ECJ Case C-550/07 P
2006
"General Report on the application of the EU Treaty freedoms to direct tax rules," International Federation of European Law (FIDE), Cyprus
2006
"Tax Law and Policy in an Adolescent EU," The Maarten Ellis Lecture, University of Leiden
1994
EC Tax Law (co-authored with Richard Lyal of the Commission Legal Service), Oxford University Press
Numerous articles on European law and tax law