John is Head of our Tax team. For more than 30 years he has advised Fortune 500, FTSE 100 and other major multi-nationals in respect of international tax especially in Ireland, the UK, and the US. His work is focused on technology companies, intellectual exploitation, 12.5% corporate tax, 6.25% knowledge box tax, share incentives, corporate inward investment, exits and remuneration of foreign assignees.
He has a particular focus on advising US businesses that invest in Ireland. He has written extensively on US/Irish tax matters and has already worked on various reorganisations linked to US 2017 tax reform. He also has extensive tax controversy experience.
John was educated at the University of London LLB (Hons), is an associate of the Institute of Chartered Accountants and the Irish Institute of Tax and is a UK Chartered Tax Adviser.
- Tax - 12.5% and 6.25% Corporation Tax
- US/Irish tax including GILTI, FBII and BEAT
- M&A Tax Structuring, Share Incentives
- Acted for major US insurer in respect of establishment of Irish innovation centre including intellectual property importation.
- Acted for major US medical devices company on financing and structuring its operations through Ireland.
- Acted for major cyber security group on developing 6.25% knowledge development tax hub in Ireland.
- Acted for Juniper Networks in cross-border merger of EMEA hub to the Netherlands.
- Acted for Dragon Oil plc in cross-border merger to Malta.
- Acted for Deutsche Bank in its structured acquisition of more than 600 properties in Ireland.
- Led major tax litigation before Irish Appeal Commissioners.
- Acted as Irish tax counsel on numerous group reorganisations using Irish vehicles.
- Acted as Irish tax counsel to Berkshire Partners LLC, Advent International Corporation and Bain Capital Partners LLC in their recommended $1.1 billion acquisition by way of scheme of arrangement for SkillSoft plc.
- Acted as sole Irish tax counsel for UK quoted Vedanta Resources plc in connection with its acquisition of zinc mining interests in Ireland as part of its agreement with Anglo American plc to purchase African and Irish zinc mining interests for $1.34 billion.
- Acted as Irish tax counsel to Mylan Inc., which ranks among the leading generic and specialty pharmaceutical companies in the world, in respect of its $550 million cash acquisition of Bioniche Pharma Holdings Ltd., an Irish based global distributor of generic injectable drugs.
- Acted as Irish tax counsel to LaCrosse in respect of its acquisition from Bank of America Merill Lynch’s global alternative fund administration business that will increase the group’s funds under administration from $15 billion to $21 billion.
- Acted as exclusive Irish tax counsel to BNP Paribas in its multi-billion Euro bid for the Polish assets of AIB.
- Acted as Irish tax counsel to Samsung in its US$1 billion plus disposal of its hard Disc drive business to Irish incorporated parent, Seagate Technology.
- Acted as joint Irish tax Counsel to Odeon Cinema's in its acquisition of one of the largest cinema chains in Ireland.
- Acted for the providers of finance arranged by Merrill Lynch, Pierce, Fenner & Smith Incorporated and J.P. Morgan Securities for the $7.3bn bid by Royalty Pharma for Elan Corporation plc.
Chambers & Partners, 2019
John provides international tax advice to a broad multinational clientele. Clients remark that "he gets stuck into the deals."
Legal 500, 2018
John Gulliver comes highly recommended for ‘international corporate reorganisations’.
Chambers and Partners, 2017
"John is like a walking textbook when it comes to the international tax space."
Speaking Engagements & Teaching
- At the Annual IBA 2014 conference in Tokyo, John co-chaired the opening tax session "Life after BEPS: Is there anything left in International Tax Planning?"
- 70th Congress of the International Fiscal Association, Madrid 2016.
- John contributed to a session dealing with how multi-nationals are planning for US Tax Reform at the AICPA and CIMA US Tax Reform Conference in London in September 2018.
- John is a regular contributor of articles relating to the Irish tax toolkit to International Tax Review.