Patrick Way KC > Field Court Tax Chambers > London, England > Barrister Profile
Field Court Tax Chambers Offices
3 FIELD COURT, GRAY’S INN
LONDON
WC1R 5EP
England
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Patrick Way KC
Work Department
Tax: corporate; Tax: VAT and excise, Tax: corporate and VAT/indirect; Private client - personal tax.
Position
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
Career
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.
Memberships
Revenue Bar Association; Chancery Bar Association.
Leisure
Rugby (Richmond) – director 2010-2023, contemporary art.
Lawyer Rankings
London Bar > Tax: corporate
(Leading Silks)Ranked: Tier 3Patrick Way KC – Field Court Tax Chambers ‘Boasts knowledge of the area of tax law, ability to communicate and explain complicated concepts to the client, works well with groups and teams of professionals.’
Members of Field Court Tax Chambers have appeared as advocates throughout the UK courts, as well as in the European Court of Justice, the Privy Council, and foreign courts. International taxation expert Philip Baker KC has a long record of lecturing, and is published on double taxation treaties. Head of chambers Patrick Soares advises on the structuring of land transactions. Patrick Way KC, who is a co-founder of the set, handles a broad range of matters including taxation of interest. Imran S Afzal, described as ‘a joy to watch in court’, provided advocacy in Gallaher Limited v HMRC, a dispute as to availability of domestic law tax relief which went before the Court of Justice of the European Union, one of the last British cases to do so. Dilpreet K Dhanoa appears for a broad range of clients on domestic and international tax matters, and appeared for Hargreaves Property Holdings in Hargreaves Property Holdings Ltd v HMRC, a case on the taxation of interest on overseas loans which was appealed to the Upper Tribunal.
London Bar > Tax: personal
(Leading Silks)Ranked: Tier 2Patrick Way KC –Field Court Tax Chambers ‘Patrick has a wide scope of expertise in the area of UK personal tax matters.’
Field Court Tax Chambers boasts a highly international membership, and includes a diverse range of practitioners with expertise across the EU and beyond. Patrick Way KC, who is a co-founder of the chambers, is experienced at all levels of the UK tax system and Privy Council, with ‘a wide scope of expertise in the area of UK personal tax matters.’ Philip Baker KC has a long record as a lecturer in tax law, and has expertise in international matters. Head of chambers Patrick Soares advises on a broad range of matters, including the structuring of major land transactions. Imran S Afzal ‘excels in drafting clear, coherent pleadings and skeleton arguments’, and represented HMRC as sole counsel in the Court of Appeal in Candy v HMRC, which related to whether a claim for repayment of stamp duty land tax by the property developer and Convervative Party donor Christian Candy was made in time.