Field Court Tax Chambers

David Southern

Revenue law and judicial review. Recent cases: VAT Allegion (UK) nLtd v R & C Comrs TC/2021/0155 SilverDoor Ltd v R & C Comrs TC/2019/02830 R & C Comrs v NHS Lothian Health Board UKSC 2020/135 (Supreme Court) Milton Keynes Hospitals NHS Foundation v R & C Comrs [2021] STC 1395 Saint-Gobain Building Distribution Ltd v R & C Comrs [2019] SFTD 924 Kinnerton Confectionery Ltd v R & C Comrs (First-tier Tribunal) [2018] STFD 1256 Copthorn Holdings Limited v R & C Comrs (No 2) [2016] SFTD 17 BAA plc v R & C Comrs  [2013] STC 752 Direct Taxes Ardeshir Naghshineh v R & C Comrs [2022] EWCA Civ 19. [2022] STC 177 (Court of Appeal) Heather Whyte v R & C Comrs [2021] UKFTT 0270 (TC) Charles Tyrwhitt LLP v R & C Comrs [2021] STC 1426 R & C Comrs v Premier Picture Ltd [2021] SFTD 977 Hopscotch Ltd v R & Comrs [2020] UKUT 0294 (TCC) Airways Pension Scheme Trustee Ltd v Fielder [2019] EWHC 3032 (Ch) (High Court) Vaccine Research Limited Partnership v R & C Comrs (First-tier Tribunal) Brain Disorders Research LP v R & C Comrs [2018] STC 2355 (Court of Appeal) Coin-A-Drink Ltd v R & C Comrs  [2017] STC 1351 Judicial review R (on the application of Cartref Care Home Ltd) v R & C Comrs (Administrative Court) [2020] STC 516, EWHC 3382 (Admin) R (on the application of Carlton) v R & C Comrs  [2018] STC 589 R (on the application of Rowe) v   R & C Comrs   [2018] STC 462 R (on the application of Graham) v R & C Comrs (Administrative Court)  [2017] STC 1 R (on the application of Walapu) v R & C Comrs [2016] STC 1682 R (on the application of De Silva) v R & C Comrs  [2016] STC 1333

Dilpreet K Dhanoa

Dilpreet K Dhanoa has a diverse practice in Revenue law across both indirect and direct taxes, nationally and internationally. She joined Field Court Tax Chambers from private practice working in international arbitration and litigation, focusing on commercial disputes and advising on the implementation of VAT in the Middle East. She has appeared in all levels of Court up to the Court of Appeal. Dilpreet has a broad advisory practice and regularly undertakes litigation, and has been appointed as junior counsel to the Crown (C Panel).  She is a chapter editor for Gammie & De Souza on Land Taxation, Supperstone & Goudie on Judicial Review and also a regular contributor to British Tax Review, Taxation and Tax Adviser.  Dilpreet sits on the Advisory Boards of Oxford Women in Law and H&I on European Taxation. She is a periodic guest lecturer at the University of Oxford and King's College London and often speaks on a variety of topics pertaining to a variety of matters on taxation and commercial litigation. Prior to joining the independent Bar, Dilpreet qualified as a Chartered Tax Advisor with a Big-4 Accounting firm, specialising in the taxation of financial instruments and real estate and more recently was the recipient of the London Tax Society and CIOT's Tax Writing Competition (2021).

Imran S Afzal

Barrister at, and co-founder of, Field Court Tax Chambers. Has a broad advisory and litigation practice, including domestic and international matters for private clients, companies and revenue authorities (UK and foreign). Appointed to the Attorney General's A Panel in 2022.

Patrick Way

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

Patrick C Soares

General taxation with special emphasis on the taxation of trusts, international tax, taxation of UK property transactions and value added tax.

Peter Vaines

All areas of tax, with special emphasis on residence, domicile, trusts, international tax, income and capital taxes. Peter advises on all areas of personal and corporate taxation with particular emphasis on high net worth individuals and their businesses. He is a leading authority on the law of residence and domicile. He qualified as a chartered accountant in 1972 and was the tax partner of a firm of accountants for 25 years. He was called to the Bar in 1989 but did not commence legal practice until 2000 when he joined an international firm of solicitors where he was involved in a number of high profile cases. He is also a Fellow of the Chartered Institute of Arbitrators, a member of the Institute of Taxation and served as a Justice of the Peace for Inner London for 20 years.

Philip Baker

Works in most areas of revenue law, with particular emphasis on international tax and European Union tax law. Particular interest in taxation and the European Convention on Human Rights. Recent cases include Apple (CJEU), GEFI (UT) and Fisher (Supreme Court). Current cases include a State Aid case for the UK Government. Adviser on drafting of Mauritius Income Tax Act, and counsel for Mauritius Revenue Authority in appeals to Privy Council (CIEL, De Marroussem, Jauffoor, Bikeworld, Chiniah, Mirbel, Royal Gardens, NTA, Sharon, Total, CWA, Grove Park, Blue Lagoon). Expert witness on international tax for cases in US, India, Australia, Norway, Trinidad & Tobago and in international arbitrations; advice on taxation in connection with Gibraltar, Hong Kong, India, Singapore, Uganda, UAE and Grenada. He has chaired cross-border arbitration under tax treaties.

Riya Bhatt

Barrister at Field Court Tax Chambers, developing a litigation and advisory practice.