Gerald Montagu joined Gide's London office in 2019 where he leads our international tax practice. His practice spans cross-border advisory, contentious and transactional tax, for both companies and individuals. He has particular experience in relation to financing transactions and the taxation of financial institutions.
Gerald is the General Editor of Norfolk and Montagu on the Taxation of Interest and Debt Finance published online by Bloomsbury Professional, which has been recognised as a seminal work in its field. He has also contributed to Taxation of Interest under Domestic Law, EU Law and Tax Treaties ed Prof G Maisto (IBFD, 2022) - 'Double Source' and, with Felicity Cullen KC, 'United Kingdom').
Gerald has also published articles with the British Tax Review on the characterisation of debt issued by foreign states ('Is a foreign state a body corporate?' (2001)) and foreign entity classification ('Anson and Entity Classification Revisited in the light of Brexit: can an LLC constitute a 'body corporate' (2016)), as well as on the source of interest ('Ardmore: some Reflections on "Practical Approach" to identifying the Source of an Interest Payment' (2020)) and for The Tax Journal (including: 'HMRC: 'they' or 'it?'' (27 November 2020), 'JTIAC reaches the Upper Tribunal: onward through the Slough of Despond, but for which purpose?' (2023) and '2023: a parting glance in the rear view mirror for corporate tax practitioners' (2023)) as well as contributing to Tax Notes International ('Loans With Unallowable Purpose Vex U.K. Courts' (2023)) and ‘U.K. Court of Appeal Renders Kwik Decision on Unallowable Purpose’ (2024)).
Gerald is a member of the Loan Market Association's Tax Committee, HM Revenue and Custom's IFRS 9 Working Group, the Law Society's Corporation Tax Sub-Committee and Lexis/Nexis PSL's Consulting Editorial Board.