Image of Gareth Banfield

Gareth Banfield


Gareth has a very broad practice and advises on all aspects of corporate tax and VAT.

His experience includes advising on the tax aspects of complex domestic and international financing transactions including bank and project finance, capital markets transactions, securitisations, derivatives and structured finance transactions as well as advising on tax issues on corporate transactions including mergers, acquisitions and joint ventures, corporate restructurings and reorganisations and private equity transactions. He also advises on tax disputes and investigations and has experience assisting companies through HMRC’s high risk corporates programme and in litigating tax matters.

Gareth works with banks and other financial institutions, corporates, private equity and fund clients across jurisdictions and in multiple sectors and is recognised by clients and peers alike for the breadth of his tax experience covering a wide range of tax matters.



Representative matters

A major banking group on the tax consequences of the ring-fencing of its UK retail banking operations, pursuant to the Financial Services (Banking Reform) Act 2013 including setting up operational service companies to serve both the ring fenced bank and non ring-fenced banks.

Successfully litigating a VAT case before the First Tier Tribunal for a financial institution.

A major banking group on the tax consequences of the structuring and implementation of the recapitalisation plan for the Bank which involves a consensual bail in of subordinated debt (the first of its kind in the UK) and a highly structured capital contribution of GBP450m from the Group to the Bank, involving a debt/equity conversion effecting a change of control of the Bank and implementation of inter-conditional liability management exercises by way of exchange offers and an English scheme of arrangement.

A major UK company on settlement discussions with HMRC as part of their High Risk Corporates Programme in relation to certain financing arrangements with an amount of tax at stake in excess of GBP100m.

Pro bono




Solicitor, England and Wales, 2002


LLB, Law, University of Essex, 1988


A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.