Private client: personal tax in London Bar

Pump Court Tax Chambers is the ‘pre-eminent tax set with excellent barristers at all levels.’ It continues to thrive as is evidenced by Elizabeth Wilson QC  taking silk in 2021 and its ongoing involvement in various key cases. Highlights included William Massey QC acting (jointly with Emma Pearce) as an expert witness by providing a report for the Royal Court of Guernsey on the UK inheritance tax treatment of a Guernsey law settlement that had been established by a non-domiciled, non-resident individual in 2002. In R (Locke) v HMRC, David Ewart QC was recently instructed by the taxpayer in a judicial review about whether, and under what circumstances, follower notices and Accelerated Payment Notices should be issued.

Devereux Chambers   is ‘excellent’ and is ‘strong and up with the best.' A high proportion of its work is advisory but its members are adept at handling complex disputes too. Aparna Nathan QC continued to act for the HMRC in Beadle v HMRC, a case which considers the use of partner payment notice penalties. In Gaines-Cooper v HMRC, Akash Nawbatt QC is representing the HMRC at all levels all the way to the Court of Appeal in a multi-million pound domicile and residence appeal which also involves other issues such as transfer of assets abroad.

Old Square Tax Chambers has a particular focus on private client work and advising high-net-worth private clients on a variety of complicated UK and offshore issues. James Kessler QC continues to advise a Greek shipowner whose domicile is being challenged by the HMRC. In another key matter Robert Venables QC is advising on complex issues of residence and the domicile of the appellant in an ongoing matter. Rory Mullan QC, who took silk in 2021, continues to represent the Fisher family in its long running dispute with the HMRC over the tax consequences of the sale of part of the Stan James betting business.

Wilberforce Chambers has an illustrious history of advising on the taxation of trusts and estates as well as on the taxation aspects of pension schemes and capital gains tax. In the case of Gareth Clark v HM Revenue and Customs, which reached the Court of Appeal, Jonathan Davey QC is acting for HM Revenue and Customs in a test case concerning the liberation of pension funds through the setting up of UK and offshore trusts and other such structures.

Field Court Tax Chambers advises governments, multinational companies and others such as wealthy individuals and charities. The set of chambers has been busy advising on various significant matters. Patrick C Soares is acting for the appellant in Walewski v HMRC. The case is being considered in the Upper Tribunal and is examining a limited liability partnership in which both he and a limited company were partners, with at issue if the profit shares that were allocated to the company could be reallocated to the appellant pursuant to the 2014 ‘mixed partnership rules’. In another key matter Patrick Way QC acted for an individual in a dispute about the ordinary residence of an individual.

Temple Tax Chambers excels at international work and specialises in advising on offshore trusts, residence and other domicile matters in addition to estate planning. Members are praised for their ability to provide ‘very pragmatic solutions.’ In Fowler v HMRC, A 2020 Supreme Court case, Jonathan Schwarz acted for a South African resident who was working in the UK North Sea as a diver, at issue was the interaction of UK tax law's bespoke treatment of divers and tax treaties. Schwarz also assisted in an Australian tax case concerning the non-discrimination article in the UK-Australia tax treaty, as applied to a British citizen subjected to the "backpacker tax", which means those on working holidays do not benefit from the Australian tax-free allowance.