Regarded as an ‘elite set of specialist tax chambers’ Field Court Tax Chambers hosts a range of key players across international tax, property taxes and estate planning such as governments, large enterprises and individuals. Philip Baker KC is noted for appearing before the Court of Appeal in GE Financial Investments v HMRC, while Patrick Way KC is well regarded for his wide-ranging experience in this area. Recently taking silk, Imran Afzal KC handles a wide range of international matters, and has recently taken on matters relating to taxation reliefs on research and development.
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Profile
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 (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 [2018] (Upper 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] (interaction of income tax and capital gains tax); 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, high-value divorces; new long-term residence rules; new BPR and APR rules, Insurance Premium Tax and all areas of tax, both 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.
Memberships
Revenue Bar Association; Chancery Bar Association.
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Testimonials
Collated independently by Legal 500 research team.
- 'A great range of talented tax professionals from a variety of different backgrounds.'
- 'Very helpful and efficient Chambers.'
- 'Field Court Tax Chambers is an elite set of specialist tax chambers. It has a mix of strong litigation practitioners and advisory specialists. It has a strong international flavour with a unique system of linking with pre-eminent barristers in other jurisdictions as door tenants so that it can access first-hand experience from across the globe. Its barristers are leading practitioners, authors and lecturers, and you really couldn't find a better set.'
- 'Full of experienced and friendly barristers, all of whom are a pleasure to work with.'
- 'The Chambers are well presented and the environment allows conferences to be informal, interactive and therefore always helpful.'