Jamie Muirhead is a tax partner at Wilder Coe Ltd since April 2024, based in the City of London.

He advises on all aspects of UK tax compliance, with a particular focus on corporate and business taxes and cross-border work, and currently leads the Corporation Tax team at Wilder Coe Ltd.

Jamie also provides commercially focused tax advice to large corporate groups, international businesses and owner-managed companies across the full spectrum of UK business taxes.

He is experienced leading cross-border tax projects, M&A transaction support assignments, restructuring and reorganisation, and strategic advisory work, including to private equity-backed businesses and investors, and is known for providing practical, commercially driven advice aligned to wider business objectives.

He is a Chartered Tax Advisor (CTA) and a Chartered Accountant (ACA)

Areas of Expertise

• UK corporation tax and business taxes
• Cross-border & international tax
• Large corporate groups
• Transaction tax, M&A transaction support and tax covenant advice
• Tax-efficient acquisition and finance Structuring
• Tax due diligence
• Tax efficient exit structuring
• Group reorganisations
• HMRC enquiries & tax risk management
• Tax expert witness work and tax advice in the context of disputes

Experience

Jamie advises businesses on complex corporation tax and wider business tax matters, with particular expertise in transactions, structuring and international tax issues.

Representative experience includes:

• Advising on a series of complex deals in the hospitality sector, from refinancing with an international private credit lender on gross assets in excess of £1billion, to a landmark hotel sale in central London.
• Assisting an overseas buyer on the purchase of a small UK trading business, using both group and 3^rd party funds, delivering tax efficient finance and acquisition structuring advice and implementation assistance, together with due diligence and SPA support.
• Assist UK and international groups on cross-border structuring, expansion projects and tax risk management, including in respect of international employees and global talent acquisition, managing payroll, VAT and permanent establishment risk.
• Advise an emerging VC fund on the restructure of investment holdings and financing loans to facilitate future growth plans.
• Assist an owner managed cross boarder group on a tax efficient management incentive plan and ‘buy-in’.
• Advising large corporate groups on tax governance, risk management and HMRC matters, group interest and loss planning, and on implementation of the response to legislative changes, including the corporate interest restriction, electricity generator levy and pillar 2.
• Providing expert advice and input on commercial matters including tax cashflow modelling and investment analysis.
• Acting as tax expert and advisor in commercial disputes and litigation matters, including in respect of a liquidated damages claim under an SPA, shareholder disputes, and the quantification of latent uncrystallised tax liabilities in a family dispute with cross-boarder marital assets.

Jamie works closely with boards, CFOs, investors, lawyers and corporate finance advisers to deliver commercially focused solutions on complex tax matters.

Professional Memberships

• Member of The Institute of Chartered Accountants in England and Wales (ICAEW)
• Member of the Chartered Institute of Taxation (CIOT)

Qualifications

• BA (Hons) Cantab
• ACA
• CTA

Daniel is based in the City of London and has extensive experience (since 1993) in the resolution of business-related disputes as a forensic accountant expert witness, ADR early neutral expert evaluator, expert determiner or arbitrator. He acts across a wide range of industries and specialises in contested accounting, financial loss and share valuation issues in M&A, shareholder, partnership and other complex disputes, including fraud. Daniel is a Chartered Accountant and a Chartered Arbitrator.

Areas of Expertise

• Forensic Accounting
• Early Neutral Expert Evaluation
• Expert Determination
• Arbitration

Experience

Case Experience Includes:

• Business disputes (contract, negligence, loss of profits, business Interruption)

• Shareholder disputes (contested share valuations, unfair prejudice)

• M&A disputes (warranties, completion accounts, purchase price adjustment, deferred consideration)

• Partnership disputes

• Fraud

Representative experience includes:

• Forensic accountant expert witness for the claimant, proprietor of a leading consumer brand, in relation to a counter- claim by its licensee. The licensee claimed substantial financial losses particularly loss of profits, for alleged early termination of the brand licencing agreement in breach of its terms.
• Forensic accountant expert witness for the claimant, an industrial conglomerate, in a claim under an indemnification agreement made in a preceding group reorganisation. The remit involved assisting the Court address certain complex factual issues by reference to the historic financial and management information available. 
• Forensic accountant expert witness for the defendant, majority shareholder in an established operator of nightlife entertainment venues, in a S994 CA 2006 unfair prejudice claim by the minority shareholders in the subject group of companies. The remit concerned the valuation of the minority shareholding for compensatory buyout purposes and on a basis directed by the Court to allow for sale of business at under value and other issues in respect of which complaint had been made. 
• Forensic accountant expert witness for the defendant, a specialist medical equipment manufacturer, in a claim in international arbitration proceedings for breach of commercial agency agreement by its overseas distributor.  The remit concerned the claimed loss of profits and the quantum thereof. 
• Forensic accountant single joint expert (SJE) in a claim for loss of opportunity by an engineering company arising from its claimed loss of a corporate acquisition opportunity due to alleged fraudulent misrepresentations by the vendors of the previous company it had acquired.   The remit concerned assessment of the claimed financial losses including loss of capital value had the second acquisition taken place. 
• Forensic accountant expert adviser for the claimant, the liquidator of a group of companies, in a misfeasance claim against directors for alleged unlawful distributions. The work included detailed consideration and forensic analysis of the available accounting and other evidence in connection with the subject issue, the relevant group entities, the applicable accounting and company law regimes, matters concerning capital reductions, solvency statements and contingent liabilities, and monetary flows.  
• Forensic accountant expert adviser for the defendant, proprietor vendor, in mediation proceedings in a claim for breach of warranties and misrepresentation in connection with the sale of a specialist international media company. The remit concerned the financial loss claimed including in relation to the valuation of the subject company. 
• Independent accountant expert determiner in a share purchase agreement (SPA) dispute about the completion accounts for acquired market leading niche technology manufacturer. The dispute involved issues of jurisdiction and complex contractual requirements including the application of globally accepted international accounting principles (IFRS). 
• Independent accountant expert determiner in a shareholder dispute involving a multi-generational family business operating a chain of niche retail shops and engaged in property investment and development. The issue for determination was the valuation of the issued shares for the purposes of the buy-out of the outgoing group of shareholders. 
• Independent accountant expert determiner in a share purchase agreement (SPA) dispute about the deferred consideration based on and subject to the acquired company achieving defined levels of financial performance in the set earn-out period. The reference included preliminary issue determination in respect of jurisdiction, and analysis and consideration of numerous matters of accounting treatment and in relation to contractual arrangements  
• Sole arbitrator in a statutory arbitration. The dispute concerned business disruption and financial compensation (including loss of profits) resulting from extensive and long running street works near the subject business, a new and used car dealership located on a high-street of a regional town, by a utilities company. 
• Sole arbitrator in a commercial dispute concerning alleged breaches of a contract between the parties in a supply chain for public services. The matter involved complex end user charging arrangements and fee charging arrangements between the parties.  
• Sole arbitrator in a partnership (1890 Partnership Act) dispute concerning a law firm specialising in litigation. The matter involved many parties, numerous legal, procedural, accounting and valuation issues, and a required series of arbitration awards.   
• Independent accountant early neutral expert evaluator, in a shareholder/ director dispute concerning director’s expenses. The subject entity operated hospitality industry sites at various regional towns. 
• Independent accountant early neutral expert evaluator, assisting founder and new investor shareholders in a group of companies resolve an issue between them about the buyout valuation of the shareholdings of the exiting founder team. The issues to address were the valuation of the subject shareholdings and the impact of minority discount (subject to strategic control considerations). The work involved consideration of valuation methodology, the inter-company trading relationship, the group’s earnings prospects, and past transactions in its shares.   

Professional Memberships

• Fellow of the ICAEW
• Fellow of the Chartered Institute of Arbitrators
• Full Member of The Academy of Experts

Qualifications

• Chartered Accountant
• Chartered Arbitrator (CArb)
• Member of the Academy of Experts (MAE) and Qualified Dispute Resolver