Temple Tax Chambers

Alun aims to help businesses achieve their commercial objectives in the most tax efficient manner. His professional clients are for the most part accountants and the work business-orientated: * transactional work * corporate reorganisations * share buy-backs and returning capital * debt restructuring * buy-outs * transactions in securities and clearance work * employment-related securities, EMI schemes, EIS/VCT issues and so on He advises on all direct taxes in a business context, as well as SDLT and VAT. Much of his practice is advisory, whether planning, transaction-based or assisting in relation to disputes with HMRC. Typically instructions come by email and are discussed in conference or by phone. He then settles a note of the advice given. Litigation is also undertaken, usually at FTT/UT level. Alun seeks always to develop a good working relationship with his clients. Many are in contact on a regular basis, sometimes just to talk a possible matter through, as well as for specific advice. Alun believes that the better our professional clients understand what we do, and the benefits we can provide, the better the end product.

David has extensive experience of both direct and indirect taxes and of the related company, securities and trust laws. However, he is best known for his advice on the income tax, PAYE, National Insurance and capital gains tax aspects of employees’ and directors’ remuneration, incentives, and all aspects of employment-related securities and employee share plans, including devising and advising upon all forms of ‘growth share’ plans; ‘joint share ownership plans’ (which were first developed by David in 2001); tax-advantaged CSOP, EMI share option, SAYE-share option and Share Incentive Plans; Employee share plans and incentives, as well as ‘partly-paid’ share schemes; arrangements for internationally-mobile employees; and all other forms of management and employee financial participation.

Denis Edwards was called to the Bar (Middle Temple) in 2002 and admitted to the Scottish Bar as an Advocate in 2012. Following a judicial assistantship in the Court of Appeal, he developed a strong practice in public law and EU law before focusing on tax cases, with a specialism in VAT and the law on customs & excise duties.

Jonathan Schwarz

International tax disputes as counsel and as an expert and advice on solving cross-border tax problems, including cross-border mergers, acquisitions and reorganisations, investment funds and private equity, shipping, including tonnage tax, transfer pricing, cross-border employment and planning for UK non-domiciled residents, tax treaties and EU law affecting taxation.

Dealing with a wide range of tax-related issues, particularly in contentious matters. Keith has represented taxpayers (both personal and corporate) at all levels from the First-tier Tribunal to the Supreme Court in statutory appeals as well as in judicial review claims and High Court actions for the recovery of taxes overpaid. He is also an advocate of alternative dispute resolution in appropriate cases. Publications of note: joint editor of Tiley & Collison (LexisNexis); Author of Tax Chamber Hearings: a User’s Guide (Claritax Books); Author of Residence: the definition in practice (Claritax Books); Author of Guide to the Tax Treatment of Specialist Occupations (Bloomsbury).

Lyndsey Frawley

Dispute resolution Lyndsey is a specialist tax litigator with a predominantly contentious tax practice. She has worked within the field of tax litigation since 1997. With almost 20 years’ experience, Lyndsey really understands the ‘nuts and bolts’ of tax litigation and dispute resolution at all levels. Strategic thinking from the very start of a dispute between taxpayers and HMRC sets Lyndsey apart from other practitioners. Lyndsey is authorised by the Bar Standards Board to have the conduct of litigation at all levels. She is also authorised to accept public access instructions from lay clients. She is therefore able to provide a ‘cradle to grave’ approach to all her clients. She can take responsibility for a whole matter, where necessary. Such an approach is particularly helpful for those clients who do not have a dedicated tax litigation practice. She is instructed by accountants, solicitors and corporate clients directly and adopts an extremely collaborative approach to her work. As an advocate, Lyndsey appears regularly in the FTT as sole counsel. She also advises clients regarding suitable choices for leading counsel when a leader is required. When a leader is instructed, Lyndsey transitions seamlessly from having the conduct of the litigation into the shoes of junior counsel (with consequent cost benefits). Challenges to the decisions of HMRC naturally gives rise to other issues of public law and Lyndsey can advise on alternatives to tribunal proceedings in appropriate cases. Judicial review forms a core part of her practice along with proceedings in the High Court. Advisory practice Having gained substantial experience in VAT and other indirect taxes (including customs duties, landfill tax and aggregates levy) over the past 20 years, Lyndsey also provides specialist tax advice in these areas. Her knowledge and application of EU law is also substantial given her expertise in VAT and customs duties litigation and associated advisory work.

Michael Avient has 30-years of experience in tax. In his previous role as a partner, he has led the London tax investigation teams at a number of top 20 accountancy firms. During this time, Michael was responsible for litigation policy and strategy and was instructed in leading cases including R (oao Derry) v HMRC [2019] UKSC 19 and R (oao De Silva and another) v HMRC [2017] UKSC 74. His success in this area led to his team winning awards twice at the Taxation Awards.

Michael Collins

Michael practices in all areas of tax law. He offers advice on planning transactions, as well as on existing disputes with the Revenue. He regularly appears before the tax tribunals, in both direct tax and VAT appeals. In addition to appearing before the tribunals, Michael has a strong advisory practice. His particular areas of expertise are corporate reconstructions (Michael is one of the authors of the leading textbook in the area ‘Taxation of Companies and Company Reconstructions’), stamp duty land tax, trusts and inheritance tax, employment taxes and VAT.

Michael Quinlan

Michael’s specialist area of practice is stamp duties and similar transaction taxes. Michael has been advising the financial services and real estate sectors for more than 20 years and has been involved in 17 stamp tax appeals in the UK and overseas. The most recent SDRT cases involved challenges under European law and, in both matters, Michael was engaged as technical and industry consultant by the successful appellants. Michael covers all areas of Stamp Duty, SDRT, Financial Transaction Taxes globally and Stamp Duty Land Tax operational assurance and advisory. He was the advocate for the successful appellant in Save & Prosper Securities v CIR (2000) Sp.C 251. Real estate: Michael represented the Law Society of England & Wales in the consultations leading to the introduction of SDLT in 2003. He has advised large real estate funds and property companies in relation to bespoke solutions to complex transactions and reorganisations involving UK properties worth billions of pounds. He has appeared as an advocate before the Tax Tribunal and as an expert witness before the Land Tribunal.

Tax advocate and adviser with experience in all courts including the House of Lords and Supreme Court (including Forde & McHugh; Gray’s Timber; College of Estate Management, Langham v Veltema, Mansworth v Jelley and Hancock v HMRC). He has particular experience with owner managed businesses (hedge fund managers, professional service providers and highly profitable closely held businesses), employment taxation for all sizes of business, tax avoidance and has experience in all areas of taxation.

All forms of corporate and personal tax, including company reconstructions and demergers, return of capital to shareholders, substantial shareholdings, entrepreneurs relief, corporate debt, SDLT, stamp duty and SDRT.. Particular specialism in the taxation of insolvent companies, including liquidations, administrations, administrative receiverships and bankruptcy of individuals.

Revenue He specialises in all areas of revenue law, including: · Corporate and personal taxes · PAYE and NICs · Employment-related securities and share options · VAT and Duties · Pensions · Insolvency · Judicial Review/Human Rights · Proceeds of Crime · SDLT He is experienced in fiscal and commercial share and property valuation litigation. Pensions He has extensive experience in pensions litigation, advice and drafting, including: · Commercial, tax and trust aspects of corporate and executive pensions · Public sector arrangements · Investment and funding issues · Mergers and transfers · Winding up · Overseas arrangements; QROPs Employment He is regularly instructed by Government Departments, local authorities, individuals and businesses on a range of employment disputes, including: · Commercial aspects of pay and incentives · Employment related tax · Discrimination and Equal Pay · TUPE · Restrictive covenants, confidentiality and fiduciary duties · Injunctive relief · Unfair/Wrongful dismissal · EBT's/FURBS/UURBS Proceeds of Crime A prominent civil and criminal asset recovery practitioner, he has acted in criminal confiscations, cash forfeitures, and civil recovery matters and has particular experience in dealing with complex fraud, money laundering, direct and indirect tax and duties evasion, MTIC, pensions fraud and acquisitive regulatory offences.

Siobhan joined Temple Tax Chambers following the successful completion of her pupillage in April 2023. Siobhan accepts instructions from solicitors and accountants across Chambers broad range of expertise, advising on both direct and indirect taxes.

UK taxation and offshore trusts; HMRC negotiations of historic liabilities; SDLT and construction projects.

Specialises in advice and litigation in all VAT and customs and excise duty matters. Particular experience in property, financial services, charities, MTIC fraud and other investigation/dishonesty cases, classification, duty suspended movements, hydrocarbon oils and preferences, bingo duty (GPT).

Ximena Montes Manzano

Ximena accepts instructions in all areas of Chambers expertise from Solicitors, Accountants, Tax Advisers and other professionals under Licensed Access. Ximena is qualified to take direct instructions from members of the public and intermediaries under the Public Access Scheme in appropriate cases.