Temple Tax Chambers

Temple Tax is a leading specialist tax set, with members of Chambers between them covering all forms of taxation, both UK and international, corporate and private, direct and indirect. Chambers has a significant tax advisory and planning expertise, especially in the corporate sector, but also does a large amount of tax litigation.

The set: Temple Tax has been in existence at its current Temple Gardens address in London since 1934. Members have always specialised in tax, making it one of the longest established tax sets at the Bar. Now Temple Tax is one of the leaders at the Revenue Bar set apart by its accessible and client-orientated approach. Chambers’ ethos is to seek to combine the highest standards of expertise and technical excellence, with a commercial approach and genuine accessibility. With the assistance of Temple Tax’s team of excellent clerks, members work closely with professional clients to provide a dynamic service that fits their commercial requirements.

As well as being full time practitioners, members of Chambers also lecture widely, publish regularly (see below) and are active in many professional organisations.

Types of work undertaken:

Corporate/business tax: advisory and planning issues for large corporates and groups including transaction and IPO work, MBOs and corporate rescues, and for owner-managed businesses/SMEs including reconstruction and transactions in securities issues, employment-related securities issues and planning work with LLPs and partnerships, including structuring for hedge fund managers/venture capitalists.

Income tax and capital gains tax: Discovery assessments, IR35, NICs.

SDLT: planning and transactional work undertaken as well as SDLT/stamp duty advice in relation to reorganisations.

Personal tax and private client: expertise ranges from IHT planning and onshore and offshore trust issues, to offshore income tax/CGT/IHT issues including transfers of assets abroad, advising non-domiciled individuals, business property relief, entrepreneurs’ relief and judicial review against APNs.

International tax: international advice includes permanent establishment issues, double tax relief, the effect of EU law on UK legislation, international employments, supply chain structuring, internationally mobile executives.

VAT etc: expertise in VAT and customs and excise duties matters, VAT expertise covers land and buildings, charities, partial exemption, financial services, grouping, fraud/investigations, single/multiple supplies and three-year capping. Customs and excise duties matters include classification, licensing, preferences, quotas, reliefs, warehousing, duty suspended movements and seizures. Professional negligence expertise includes measure of loss in tax-related negligence claims and technical advice in general, and pensions, PAYE and NIC.

Chambers has a real tax litigation presence at all levels and has featured in many recent significant cases.

Supreme Court: Vermillion v HMRC

Court of Appeal: Skatteforvaltningen (The Danish Customs and Tax Administration) v Solo Capital Partners LLP & Ors; British Telecommunications PLC v HMRC

High Court: Claimants In the Royal Mail Group Litigation v Royal Mail Group Ltd.

Upper Tribunal: Jasper Conran (1) and JC Vision Ltd (2) v HMRC; Wyatt Paul v HMRC;Revenue and Customs v Atholl House Productions Limited; Keith Murphy v HMRC; Northern Light Solutions Ltd v HMRC; Revenue and Customs v Inverclyde Property Renovation LLP & Anor; Marlow Rowing Club v Revenue and Customs.

First-tier Tribunal (tax): Whispering Smith Ltd v HMRC; S & L Barnes Ltd v HMRC; Innovative Bites Ltd v Revenue & Customs; Jack George Yerou and Anor v HMRC; Portview Fitout Ltd v HMRC; Albatel Ltd v HMRC; Taska Tankers Ltd v HMRC; Edwards Cumming Bruce v HMRC; Timothy Norton Motor Services & Tim Norton v HMRC; Conservatory Roofing Systems Ltd v HMRC; Padfield & Ors v HMRC; HMRC v Premiere Picture Ltd; Peter Marano v HMRC; Albany Fish Bar Ltd v HMRC; Southend Football Club v HMRC.

Publications: Alun James and Michael Collins co-author: Bramwell on Taxation of Companies and Company Reconstructions; Michael Sherry: Whiteman and Sherry on Income Tax and Whiteman and Sherry on Capital Gains Tax; Jonathan Schwarz: Schwarz on Tax Treaties, Annotated UK Double Tax Treaties (6th ed), Booth and Schwarz: Residence, Domicile and UK Taxation (21st ed), and Transfer Pricing and Business Restructurings: Streamlining all the way. Philip Ridgway is co-author of Bloomsbury Professional’s Tax Indemnities and Warranties. David Pett: “Employee Share Schemes” (2-Vol loose-leaf and online pub. Thomson Reuters); “Disguised Remuneration and the Loan Charge” (Claritax Guide 2020); “Tiley & Collison’s UK Tax Guide” 2018-19 (contributor);’; Keith Gordon & Ximena Montes Manzano co-author Tiley & Colinson UK Tax Guide 2019; Ximena Montes Manzano: Main Residence Relief (3rd ed); Keith Gordon: Tax Appeals, Law and Practice at the FTT (5th Ed)