A number of our members have significant experience of a wide range of high profile and high value direct tax litigation and related advisory work, particularly in areas where multi-disciplinary skills come to the fore.
Many of the cases in which members of Chambers have acted have involved cross-over with expertise in the areas of commercial law, complex financial instruments, valuation, company law, insolvency and professional negligence. Members regularly act in litigation at all levels from the First-tier Tribunal to the Supreme Court. Direct tax work undertaken is frequently for the Crown, but litigation and advisory instructions are also welcomed on matters with direct tax angles for private individuals and corporations.
One of our members was recently short-listed for Tax Silk of the Year by Legal 500, and a number of other members are well-known for their work involving tax.
Some of our recent noteworthy cases include:
- Hancock v HMRC (2019) (Supreme Court): correct tax treatment of loan notes issued pursuant to a takeover
- Joint Administrators Of Lehman Brothers International (Europe) (In Administration) v HMRC (2019) (Supreme Court): whether statutory interest payable in an administration amounted to "yearly interest" under the Income Tax Act 2007 s.874)
- Smith & Nephew Overseas v HMRC (2020) (Court of Appeal): recognition of foreign exchange gains and losses as a result of group restructuring
- Inmarsat v HMRC (2021) (Upper Tribunal): capital allowances on the launch costs of six leased communications satellites