Gerald Montagu
Partner
Gerald has a broad international tax practice, spanning advisory, contentious and transactional tax advice, for both companies and individuals.
Biography
Language - English
Jurisdiction - England & Wales
Gerald has particular experience in relation to financing transactions (including asset and trade finance and securitisation), funds (private equity and credit funds), financial institutions (banks and insurance companies), real estate, and projects/infrastructure. He also advises private clients and family offices.
Since 2009 Gerald has been general editor of the leading work "Norfolk and Montagu on the Taxation of Debt Finance", published online by Bloomsbury Professional (Bloomsbury). He was named as a Thought Leader by Lexology in the 2026 edition of Thought Leaders Tax.
Experience
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Personal Tax
Advising over many years in relation to the largest privately held portfolio in an area of North London.
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Structured and Asset Finance
Europcar - tax advice in relation to the establishment of a £450 million hire purchase based securitisation programme in the UK and advice in relation to a €2 billion EU securitisation programme.
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Projects and Infrastructure
Delta Offshore Energy - multi-jurisdictional tax advice in relation to a proposed $4 billion 3,200 megawatt gas fired power plant in Vietnam.
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Marine and International Trade
The World (formerly The World of ResidenSea) - general tax and structuring advice.
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Contentious Tax
Successful settlement of HMRC enquiries in relation to an EIS investment, a film scheme, and a COP 9 enquiry for an international bank, advice for an offshore insurance company undergoing a chargeable event audit and for a family in relation to incorrect tax advice.
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Funds and Financial Services
Rothschilds Investment Management and Tikehau in relation to various credit funds and CIC Private Debt in relation to CLOs.
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Hotels and Leisure
Hard Rock Group - tax advice in relation to its events, hotels and restaurants.
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Private Equity
Talend SA - UK tax advice on its $2.4 billion pre-disposal restructuring and acquisition by Thoma Bravo.
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Real Estate Investors and Developers
K&C Residential REIT PLC - tax advice on restructuring prior to entry into the REIT regime and becoming a REIT.
Authorships
- Norfolk and Montagu on the Taxation of Interest and Debt Finance (Bloomsbury, online, updated quarterly)
- Legal Practice Companion (Blackstone, Oxford University Press and Bloomsbury, 1995-2014)
- Taxation of Interest under Domestic Law, EU Law and Tax Treaties (IBFD, 2022, with Felicity Cullen KC, ed Prof Guglielmo Maisto (Maisto)
- The Law of Global Custody (Bloomsbury, 2025, with Madeleine Yates)
- Revisiting Concepts of Abuse and their Relationship with International and EU Tax Law (IBFD, forthcoming 2026, ed Maisto)
British Tax Review
- 'Is a foreign state a body corporate?' (2001)
- 'Anson and Entity Classification Revisited in the light of Brexit: can an LLC constitute a 'body corporate' (2016)
- 'Ardmore: some Reflections on the "Practical Approach" to identifying the Source of an Interest Payment' (2020)
Tax Journal (not exhaustive)
- 'HMRC: 'they' or 'it?'' (2020)
- ‘A cautionary tale: how to fail to show accounts are GAAP-compliant’ (2024)
- ‘Tax, memory and the written record: revisiting Gestmin’ (2024)
- ‘Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle’ (2025)
Tax Notes International (not exhaustive)
- 'Barclays’ UK Tax Tribunal Troubles Spill Into Transfer Pricing' (2025)
