Field Court Tax Chambers

Tax: corporate; Tax: VAT and excise, Tax: corporate and VAT/indirect; Private client - personal tax.

All areas of tax, both as an adviser and an advocate. Queen’s Counsel 2013. Previously, Attorney General’s B Panel member as junior counsel to the Crown. Cases include: Hargreaves v HMRC (UT) (listed for Court of Appeal - meaning of beneficial entitlement and short interest) McCabe v HMRC (First-tier Tribunal, discovery of MAP documents); MDU v HMRC (First-tier Tribunal, mutuality); Davies & Others v HMRC (Upper Tribunal, TOAA & DTA); Ardmore Construction Ltd v HMRC (Court of Appeal, source of interest); Mackay v HMRC [2017] (First-tier Tribunal, ordinary residence, taxation of UURBS, source of employment income); Christianuyi v HMRC [2016] (managed service companies); Steven Gray v HMRC [2016] (First-tier Tribunal, losses as promoter of musician); Glyn v HMRC [2015] (Upper Tribunal, residence of an individual and the fact finding task to be carried out at first instance); Perrin v HMRC [2014] (First-Tier Tribunal, source of interest); Interfish v HMRC [2013] (Upper Tribunal, wholly and exclusively test); Blumenthal v HMRC [2012] (First-Tier Tribunal, discovery and cgt planning); de Maroussem v Mauritius Revenue Authority [2011] (Privy Council, meaning of ‘development’); Rogers v HMRC [2010] (First-tier Tax Tribunal, meaning of ‘emolument’); Blackburn v HMRC Court of Appeal [2008] (availability of EIS relief); Drummond v HMRC Court of Appeal [2008]; Ashley v HMRC Special Commissioners [2007] (EIS claim); Madeley and Finnigan v HMRC (‘The Richard and Judy case’), Special Commissioners [2006]; Andre Agassi v Robinson (HMIT), House of Lords [2006] (taxation of foreign entertainers); Andre Agassi v Robinson (HMIT) (2) (Bar Council and Law Society intervening), Court of Appeal [2005] (efficacy of Licensed Access Scheme and ability to recover accountants’ costs); Re: Executors of Dr Harvey Postlethwaite, SpC [2006] (the effect and ambit of s10 Inheritance Tax Act 1984 (non-gratuitous transfers); recent matters include major real estate transactions, corporate acquisitions and re-organisations, MBOs, international tax questions, SPA disputes, intermediary legislation, new partnership legislation, insurance related taxation, planning involving partnerships, unit trusts and EBTs; discovery disputes; rectification of overpaid tax; disputes re individuals’ residence; SDLT disputes and planning; film schemes; deductibility; tax schemes; inheritance tax planning; entrepreneurs’ relief, agency rules, MSCs, charities, remittances, domicile disputes, corporate structuring, M&A advice, divorce; new non-dom rules; and most areas of tax, direct and indirect. Forthcoming Tax Tribunal case in relation to Insurance Premium Tax

Called 1994, Lincoln’s Inn; QC 2013; previously a solicitor, admitted 1979; partner at two leading law firms, first at the age of 31; has written and edited books and chapters on groups of companies, joint ventures, the business expansion and enterprise investment schemes, the tax planning of individuals and on stamp duty and stamp duty land tax. Lectured throughout the world on all areas of tax. Times’ Lawyer of the week; Counsel magazine’s barrister of the month. Accountancy Age’s Top 50 Financial Power List.

Revenue Bar Association; Chancery Bar Association.

Rugby (Richmond) - director 2010-2023, contemporary art.