Edward Gibson

Ed is a corporate and international tax partner at S&W, advising businesses across the UK on domestic corporate and international tax matters. Ed’s work has a particular focus on expansion, business change and cross-border complexity — helping groups enter new markets, adapt their operating models, restructure, and manage the tax implications of financing, supply chains, intellectual property and profit repatriation.

Areas of expertise include:

• Permanent establishment risk and tax residency
• Transfer pricing
• Withholding tax and double tax treaties
• Anti-hybrid rules and CFCs
• Pillar Two
• Diverted profits tax
• Substantial shareholding exemption
• Group reorganisations, acquisitions and disposals
• HMRC enquiries

Experience

Ed has 25 years’ experience in corporate and international tax, gained across both Big 4 and mid-market firms. Ed’s clients have included listed and multinational groups, private equity-backed businesses, privately owned companies and growth businesses, across sectors including consumer, retail, technology, manufacturing and professional services. Ed has particular depth in cross-border financing, the tax aspects of international operating model design, and supporting clients through acquisitions, disposals and group reorganisations.

Ed combines technical expertise with a practical understanding of commercial objectives, helping clients manage tax in a way that supports growth, change and strategic decision-making. Ed is based between S&W’s Manchester and London offices and advises clients across the UK.

Notable client work and achievements

• Led the tax integration of a major acquisition for a global multinational, covering supply chain integration, transfer pricing, financing arrangements and tax authority engagement strategy
• Guided a fast-growing fashion brand through international expansion, covering operating model design, group set-up, permanent establishment and residency risk, funding and profit repatriation
• Advised a global consumer products group on the disposal of non-core business units, managing the tax implications of the related pre-disposal reorganisation
• Advised a large professional services group on integrating international acquisitions, resolving cross-border tax risk and designing new financing, working capital and operating model arrangements
• Led Pillar Two compliance for a large multinational group, from impact assessment through to compliance strategy and multi-jurisdiction filing obligations
• Advised extensively on anti-hybrid risk for multinational groups, including risk identification, mitigation and disclosure of historical positions to tax authorities

Professional qualifications/memberships

• Fellow of Institute of Chartered Accountants in England & Wales
• Member of the Chartered Institute of Taxation