Peter Cussons, who passed away
at the age of 60 last month, was one of Britain’s most distinguished tax practitioners. He recently retired as an international tax partner at PwC – where he led the firm’s EU direct tax group – after a long and illustrious career. After qualifying as an ICAEW chartered accountant, he started in tax in the summer of 1978 at Price Waterhouse after being offered a three-month secondment into either tax or insolvency. He qualified as an associate of the CIOT the following year and became a partner in Price Waterhouse (now PwC) in 1987. In his own words, he ‘chose tax and never looked back’.
Patient and softly spoken, yet assured and authoritative, Peter was highly respected among his peers. For a number of years he was nominated as one of the UK’s top advisers and was listed in the 2014 Expert Guides on Tax. According to those who worked with him, Peter was highly knowledgeable and highly productive. ‘Peter had a brilliant mind and an encyclopaedic command of case law by UK and EU courts’, said one. ‘His expertise and intelligence was acknowledged by the greatest minds in the field of tax law. As well as a brilliant individual, who always remained kind and modest and full of humour, he was one of life’s true gentlemen.’ Another said: ‘He was such a nice man, and so generous with his time there – and, as many have experienced, elsewhere.’
During his time at PwC, Peter was involved in various direct tax infringement proceedings by the European Commission and led or assisted some high-profile group litigation orders (GLOs) in the UK, including acting as instructing accountant in the ACT class 2 and 3 GLOs (High Court and Court of Appeal) and in the depreciation in stock case (Special Commissioners, High Court and House of Lords). He also acted as instructing accountant in the Marks and Spencer PLC v Halsey cross-border loss relief case (High Court, Court of Appeal, CJEU, First-tier Tribunal, Upper Tribunal, Court of Appeal and Supreme Court) and the recently granted 1.5% stamp taxes GLO.
‘Peter’s efforts at the firm – perhaps alongside Guy Brannan and Neal Todd, then both at Linklaters – to apply EU law to British tax law changed the face of UK tax legislation,’ said a partner who formerly worked with him at Price Waterhouse.
Peter’s enthusiasm for tax saw him volunteer for a number of committees. He was a member of the ICAEW Tax Faculty Technical Committee and chaired the ICAEW Tax Faculty’s Large Business and International Committee. Peter was also a member of the CIOT’s International Tax Committee and vice-chair of the CIOT EU and Human Rights Committee. He was also the only ‘big four’ partner on the Confederation of British Industry’s main tax committee.
Fellow committee members recalled Peter’s passion for cycling to meetings, as well as his European tax expertise: ‘Whenever and wherever I saw Peter, whether in meetings for the CIOT or at conferences, his cycling helmet was never far behind’, recalls one. ‘Professionally, I will remember him most for his mind-boggling knowledge of, and passion for, European tax law. He could quote paragraph numbers of a particular judge’s comments from cases going back in the mists of time, and enjoyed a meaty discussion on the topic at every opportunity. He could always find an EU slant on any new legislation that was being proposed, and could always be relied upon to provide a persuasive and technically detailed argument, leaving some of the rest of us in the room far behind. I will miss his input, his personality and his brilliance.’
Peter was a frequent contributor to various tax publications and was often cited in the Financial Times and other papers and journals. He was a member of Tax Journal’s editorial board and also served as a guest lecturer at Queen Mary University of London, King’s College London and the Institute of Advanced Legal Studies.
Despite his retirement, Peter continued to consult with PwC. Colleagues described his passing as a ‘huge loss to the tax profession’. Another observed: ‘His encyclopaedic knowledge, clear thinking and quiet authority will be greatly missed.’
He is survived by his wife Sheila and two daughters Alexandra and Kathryn.
You might not know this about me but at heart ...
‘As well as being an avid Tolkien fan, I’m a railway enthusiast! One of my favourite memories was standing on Penrith station in the early ‘60s, and seeing the steam-hauled express train that had just come over Shap Summit, double-headed, thundering through the curved station. It was a magnificent sight.’
