Exhibit 8.2
Navigator Gas plc
The Verde
10 Bressenden Place
London
SW1E 5DH
United Kingdom
FAO: The Board of Directors
1 September 2026
Dear Directors
Navigator Gas plc (the “Company”)
We are acting as advisers as to English law to Navigator Gas plc, a public limited company incorporated under the laws of England and Wales (the Company).
We understand that the Company has filed a registration statement on Form F-4 dated 1 September 2026 (the “Registration Statement”) with the U.S. Securities Exchange Commission. We have reviewed this Form F-4, and a copy is enclosed for reference.
We have been asked to provide an opinion on certain matters, as set out below, in connection with the filing of the Registration Statement.
We write to confirm that the subsection headed “U.K. Tax Considerations” within the section “Material Tax Considerations” contained on page 48 of the Registration Statement Form F-4 is a fair and reasonable summary of the relevant tax law and HM Revenue & Customs practice relating to the taxation of Navigator Gas plc, taxation of dividends, dispositions of the ordinary shares, stamp duty and stamp duty reserve tax as at the date of this letter.
Our opinion on this matter is made on the basis that all facts, information, statements, representations, covenants, exceptions, limitations, and qualifications contained within the Form F-4 are true, complete, and correct in all respects.
Our opinion is limited to UK tax law and published practice and guidance of HM Revenue & Customs as at the date of this letter. Our opinion is provided solely in connection with the filing of the Form F-4, and on the basis that the Form F-4 is not changed from the form reviewed by ourselves as noted above.
By giving this opinion, we do not assume any obligation to notify you of future changes in law which may affect the opinions expressed in this letter, or otherwise to update this opinion in any respect.
To the extent that the laws of any other jurisdiction may be relevant, our opinion is subject to the effect of such laws. We express no views in this opinion on the validity of the matters set out in any opinion given in relation to such laws.
We have not been responsible for verifying whether statements of fact (including foreign law), opinion or intention in any documents referred to in this opinion or in any related documents are accurate, complete or reasonable.
We hereby consent to the filing of this letter as an exhibit to the Registration Statement, the discussion of this opinion in the Registration Statement and to all references to our firm included in or made a part of the Registration Statement. In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act, or the rules or regulations promulgated thereunder, nor do we admit that we are experts with respect to any part of the Registration Statement within the meaning of the term “expert” as used in the Securities Act or the rules or regulations promulgated thereunder.
| Yours faithfully |
| /s/ Watson Farley & Williams LLP |
| Watson Farley & Williams LLP |
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