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Chambers Of Patrick C Soares

3 FIELD COURT, GRAY’S INN, LONDON, WC1R 5EP, ENGLAND
Tel:
Work 020 3693 3700
DX:
374 LONDON CHANCERY LANE
Email:
Web:
www.fieldtax.com

Patrick Way QC

Tel:
Work 020 3693 3700
Email:
Field Court Tax Chambers (Chambers Of Patrick C Soares)

Work Department

Tax – corporate; tax – VAT, C&E; 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: HMRC v Root2 Tax and anor (2017) (First-tier Tribunal, DOTAS application, Wilberforce rule, application of Abbott v Philbin); 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); Ardmore v HMRC [2016] (Upper Tribunal, source of interest); 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.

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.

Member

Revenue Bar Association; Chancery Bar Association.

Leisure

Rugby (Richmond) - director, contemporary art.


London Bar

Private client: personal tax

Within: Private client: personal tax – Leading silks

Patrick Way QC - Field Court Tax ChambersHe is very efficient and approachable.

Within: Private client: personal tax

Members of Field Court Tax Chambers are ‘highly spoken of’ and are skilled at tax litigation and international advisory work. Patrick Way QC is acting for the taxpayer in Tony Mackay v HMRC, a major case about the ordinary residence status of an individual.

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Tax: corporate and VAT

Within: Tax: corporate – Leading silks

Patrick Way QC - Field Court Tax ChambersHe is efficient and very approachable.

Within: Tax: corporate and VAT

Field Court Tax Chambers is a specialist tax set, members of which are regularly instructed by governments, multinational enterprises, wealthy individuals, charities, celebrities and tax authorities. Niche areas of expertise include double taxation and tax-related human rights law. Co-founder Patrick Way QC has expansive UK court experience and has also appeared before the Privy Council. Imran Afzal successfully represented the revenue before the Supreme Court in Littlewoods Ltd and others v HMRC in a case revolving around the availability of compound interest where taxpayers have overpaid.

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