Euan Palmer is a disputes lawyer at Greenwoods, advising individuals and businesses involved in complex commercial and tax related disputes. His work includes litigation arising out of historic tax planning and remuneration structures, including contractor loan and employee benefit trust arrangements.

Euan is regularly instructed in matters where claims arise long after the original arrangements were entered into, often involving issues of the nature or conditions around any alleged repayment obligations, enforceability and personal liability. These disputes frequently follow changes in “ownership” of loans, or the assignment of historic claims and require close analysis of documentation, timing and enforcement history.

He acts for both claimants and defendants and is experienced in disputes that sit at the intersection of tax, trust and commercial law. Clients value Euan’s ability to manage complex factual histories and large volumes of material while keeping advice focused on practical, realistic outcomes.

In the last year, Euan has successfully concluded a long‑running group claim against HMRC on behalf of initially more than 80 individuals, with substantial recovery of legal costs achieved as part of the process.

The claims involved challenging the legitimacy of payment notices issued by HMRC following a delayed decision that a tax saving scheme was invalid. The litigation required detailed consideration of HMRC’s use of statutory powers, the timing and basis of the payment notices, and the procedural fairness of HMRC’s approach.

The claims were structured through two separate groups of claimants, reflecting discrete differences in the schemes entered into. The payment notices were issued in varying amounts, and the group structure was designed so that contributions to legal costs were made on a proportionate basis, relative to the value of each individual’s payment notice.

Euan played a key role in managing the group structure, coordinating strategy across claimants and advisers, and ensuring that the litigation remained efficient, proportionate and commercially sensible for participants.

Euan is closely involved in Greenwoods’ work on disputes arising from employee benefit trust and contractor loan arrangements, often known as “Loan-based remuneration schemes”.

These claims commonly affect contractors in sectors such as IT, engineering and healthcare, who were advised to use trust based structures under which funds were advanced by way of loans. As the tax and regulatory landscape has changed, entities connected with those schemes, or assignees of historic loan books, have increasingly sought to recover the sums advanced.

Euan advises on the legal and practical issues that arise in these cases, including assignment, limitation, documentation gaps and prior enforcement history. He emphasises the importance of taking early, informed advice so that responses are carefully framed and options preserved.