Undoubtedly the biggest and best tax set in London.

Legal 500, 2018

  • Chambers Global (2018)

    THE SET

    Pump Court Tax remains the foremost private client tax set in England and Wales. Barristers can assist on all types of matters, such as tax planning, trusts and estates, inheritance tax (IHT) and capital gains tax (CGT). Sources say it is “the best in town for tax work” and that “it has more of an emphasis on private client than any other of the sets.” One source comments: “They are our favourite chambers for tax. They really have moved with the times and have a very proactive, friendly and collaborative manner.” Other interviewees say it is “a first-rate chambers. They are a large set and cover everything that I need,” adding: “You know what you’re getting and that is top quality. They are brilliant at dealing with ultra-complex work and always get an efficient response.” One market insider adds: “There is a depth and breadth there that you can’t find anywhere else. So many members of the chambers have been involved in the leading tax cases.”

    Client service: The clerks at Pump Court, led by Nigel Jones, are especially well regarded. One interviewee enthuses: “The clerks are all extremely helpful and easy to deal with. They are very responsive and user-friendly. I can’t think of a single instance when I haven’t been completely happy. They will always try to fit you in and make sure their barristers are delivering on time.”

    SILKS

    William Massey QC
    Best known for his private client work, with his expertise lying in trust and estate tax planning, business and agricultural property relief, heritage property and exemption. Massey’s work on complex trust and inheritance tax issues is especially noted.
    Strengths: “William is definitely frontline for IHT. When I’ve got William’s advice I will always take my time to read it carefully. He’s also very flexible, I can ring him whenever I need to and he’s always got time for the job because he’s innately interested in what he’s doing, and it shows.” “I always use him for complex matters. He is extremely thorough and learned but puts things into easily understandable language.”
    Recent work: Appeared in DC v AC, a Variation of Trusts Act case, where he succeeded in an application to extend the trust period to mitigate CGT and IHT liabilities.

    Kevin Prosser QC
    Prosser often acts on highly complex income tax and employee benefit trust (EBT) cases in the appellate courts. He also has experience on double taxation matters and sits as a deputy High Court judge.
    Strengths: “One of the best, if not the very best tax QC at the English Bar. He provides concise, technical advice in a very commercial, pragmatic manner.” “Outstanding and extraordinarily good on his feet. He is very responsive, razor sharp, and a very bright man.”
    Recent work: Acted for the taxpayer in Blackwell v HMRC, a CGT case concerning the deduction of fees against the gains from selling shares.

    David Ewart QC
    Highlighted for his work on behalf of the Revenue but also represents private clients in complex tax cases. He often advises on inheritance tax planning matters and family limited partnerships, and he has handled film finance scheme cases recently as well.
    Strengths: “He’s very clever and technically impressive.” “Extremely practical, highly intelligent and very talented.”
    Recent work: Represented the taxpayer in an IHT case involving an excluded property trust settled by a non-domicile, who later became UK-domiciled and then left the country again. The key question was whether the property had lost its IHT-exempt status permanently or whether it had regained it after the taxpayer moved away again.

    Julian Ghosh QC
    Qualified to practise in both England and Scotland, with expertise in European taxation issues. Ghosh acts for HMRC and for taxpayers on a range of personal tax matters, and has particular expertise in Agricultural Property Relief (APR) and Business Property Relief (BPR) from IHT.
    Strengths: “Of all the barristers we’ve worked with, he’s the standout.” “Renowned for being technical and solid in his approach. He is a high-quality performer.”
    Recent work: Acted for the Revenue in the Rangers tax case. The former owners of the club made tax-free loans to staff and players from EBTs. The Supreme Court found that these payments ought to have been treated as taxable earnings for NIC and income tax purposes.

    JUNIORS

    Emma Chamberlain
    A supremely respected junior, with a huge reputation for her private client expertise. Specialises in tax and trust advice, particularly on offshore trust structures, for high net worth individuals.
    Strengths: “Remains the go-to person at the private client tax Bar. She has the ear of the HMRC and, where other barristers merely assert their opinion, she tells you what HMRC’s view really is.” “She is one of the best in the UK. She is very direct and you can really see the wood through the trees. She is very good at working through reams of complex detail and at co-ordinating all third parties, like lawyers and accountants, to work as a cohesive team.”
    Recent work: Represented the taxpayer in James Glyn v HMRC, a complex residence case.

    James Rivett
    Regarded by sources as a personable and impressive advocate who is in high demand. Rivett has particular expertise in the often arcane world of variation of trust, and he is also an expert in heritage property matters for landed estates.
    Strengths: “There doesn’t seem to be any aspect of tax that James Rivett hasn’t mastered. One always feels he is very much on your side in trying to find a solution without taking silly risks, but he doesn’t shirk the difficult message.” “He really knows what he is doing. He can translate sophisticated legal issues to the layman.”
    Recent work: Acted for the Revenue in Shiner & Sheinman v HMRC. At issue was the compatibility with EU personal rights of retrospective application of the closure of a tax loophole.

    Elizabeth Wilson
    Practises in all areas of tax law. She has particular experience in APR and BPR cases, offshore trusts, partnerships and non-domiciliary tax planning.
    Strengths: “Very precise and clear in her advice.” “Highly technically competent, and has done some big cases for the Revenue.”
    Recent work: Appeared for the Revenue in Re Staveley Deceased, an Upper Tribunal IHT case.

    Richard Vallat
    A highly regarded tax barrister, who specialises in advising on offshore trusts, domiciled issues and tax planning for ultra high net worth individuals.
    Strengths: “Highly competent and good at explaining complex matters in layman’s language.” “A formidable opponent. Charming outside court and very much fights his corner in court.”
    Recent work: Acted for HMRC in a conjoined income tax appeal before the Supreme Court, concerning the tax treatment of two complex employee share bonus schemes.

    Laura Poots
    Particular expertise in offshore trust and family partnership structuring and domicile matters.
    Strengths: “She is always happy to discuss problems, responds very promptly and her advice is sound.” “Her written advice is clear and precise and a joy to read.”

    Ian Richards
    A highly regarded tax barrister, who specialises in advising on offshore trusts, domiciled issues and tax planning for ultra high net worth individuals.
    Strengths: “He’s very knowledgeable and careful, and drafts beautifully.”

  • Chambers & Partners (2018)

    Tax

    The Set: Pump Court Tax Chambers is widely considered the pre-eminent tax set by virtue of its unparalleled strength in depth at both the silk and junior levels. “They have an impressive range of resources, enabling them to cover all areas,” affirms one instructing solicitor. The team has expertise in the full range of corporate tax matters, from the tax treatment of dividends paid by foreign subsidiaries to challenges by HMRC of tax avoidance schemes. Additional areas of knowledge include land remediation relief and tonnage tax. Members act for the taxpayer and the Revenue and have appeared in many of the most prominent cases.

    Client service: “The clerks are amazing; very efficient and very prompt. They couldn’t be more helpful.” Senior clerk Nigel Jones is reported to be “absolutely amazing,” according to sources, one of whom comments that he is “one of the most organised and responsive clerks I’ve dealt with. He makes a real effort to know you personally and is very good at building relationships.”

    SILKS
    David Milne QC
    An iconic presence at the Tax Bar who is highly sought after for his expertise on both the contentious and the non-contentious side. His advisory practice includes assisting with high-profile M&A transactions. He regularly handles Supreme Court and ECJ briefs and wins praise for his strong advocacy in these tough cases.
    Strengths: “A great mind and an excellent advocate. He has the ability to make the complex simple.” “The original forefather of tax disputes at the Bar.”
    Recent work: Acted in Ingenious Film Partners v HMRC, a film finance scheme case involving over £1 billion of film finance transactions.

    Kevin Prosser QC
    A pre-eminent silk who acts for the Revenue and taxpayers on a range of tax issues, including challenges to major schemes. He has appeared at all levels of court and also maintains a highly respected advisory practice covering such areas as Islamic finance and transfer pricing.
    Strengths: “The most formidable barrister of his generation.” “He has a down-to-earth approach, provides clear advice and is an excellent litigator.”
    Recent work: Successfully acted for HMRC in a Court of Appeal case against Bristol & West concerning a group mismatch in derivative contracts.

    David Ewart QC
    Handles some of HMRC’s most important test cases, and also regularly represents the Revenue in group litigations. He further acts for taxpayers on significant matters in an advisory capacity and in court. Clients include accountants and multinational corporations.
    Strengths: “Responsive and reliable. He has a knack for expressing difficult concepts simply, precisely and persuasively.” “He provides clear, practical advice.”
    Recent work: Represented the Revenue with respect to a dividend and Controlled Foreign Companies (CFC) group litigation order concerning the taxation of dividends paid into the UK by foreign subsidiaries of UK companies.

    Julian Ghosh QC
    Regularly appears before the highest courts in England and Wales, and Scotland, acting for taxpayers and the Revenue. He is particularly well regarded for his work involving loan relationships and EU law. He also advises on the taxation of IP.
    Strengths: “Knowledgeable, thorough and skilled at both advocacy and specific advice.” “He has a very sharp and agile mind and is very good at shining a bright light on convoluted legislation. He is a great practitioner.”
    Recent work: Represented the Revenue in a case against Travel Document Service and Ladbroke Group International concerning a loan relationship tax scheme.

    Rupert Baldry QC
    Although best known for HMRC work, he also has an impressive taxpayer practice and has handled a number of group litigations. Many of his cases involve transfers between international arms of multinational businesses, and deal with issues such as loans to foreign subsidiaries and the taxation of foreign dividends.
    Strengths: “Very approachable, down to earth and practical.” “He is charming and very approachable.”
    Recent work: Acted for HMRC in the Franked Investment Income (FII) GLO, a case challenging the taxation of dividends paid into the UK by foreign subsidiaries of UK companies.

    Giles Goodfellow QC
    An expert on income tax and employee benefits matters. He regularly provides advice on corporate reorganisations, tax-related professional negligence and tonnage tax. He acts for both the Revenue and taxpayers.
    Strengths: “He has the ability to win difficult cases with his inventive thinking.” “Very commercial and pragmatic.”
    Recent work: Acted in Christianuyi Ltd and others v HMRC, a case regarding the Managed Service Company legislation.

    Andrew Thornhill QC
    Best known for his particular expertise in employee benefit trusts and disguised remuneration matters. He also advises on corporate reorganisations and the use of offshore structures to hold UK property assets. He has additional knowledge relating to family businesses.
    Strengths: “Extremely clever. He has a huge knowledge of tax and is very quick at grasping issues and coming up with commercial suggestions for resolving issues.” “He has an incredible depth of knowledge.”
    Recent work: Acted for the taxpayer in the Advocate General for Scotland v Murray Group Holdings & Ors PAYE case regarding the payment of national insurance contributions into an employee benefit trust (EBT).

    Roger Thomas QC
    Has extensive experience of handling challenging corporate tax matters before the highest courts. His particular area of expertise is stamp duty, and he is regularly instructed on the most complex SDLT cases. He acts for a diverse set of clients including accountants, City firms, museums and political parties.
    Strengths: “”Exceptional, audacious intelligence, combined with a pleasant and constructive manner.” “User-friendly, clear and definitive advice.”
    Recent work: Acted for the taxpayer in a large-scale SDLT case concerning the acquisition of the Chelsea Barracks site.

    JUNIORS
    Jonathan Bremner
    Leading junior with an impressive track record of acting in heavyweight litigation. He is often instructed in major employee benefit trust cases and group litigations. He also advises in relation to reconstruction, transfer pricing and other matters.
    Strengths: “A brilliant senior junior, equally at home advising on a technical argument or in the courtroom.” “He has a wonderful calm manner which can lead the client or the judge through very complex facts and law with brevity and clarity.”
    Recent work: Acted in the dividend and CFC GLO, a case concerning the taxation of dividends paid into the UK by foreign subsidiaries of UK companies.

    James Rivett
    Highly regarded tax junior with a broad-based corporate tax practice. He acts with a leader on many significant instructions and also leads his own cases, often appearing against silks. He represents both the Revenue and the taxpayer.
    Strengths: “A great junior. Very commercial, adept at building client relationships and technically sound.” “Helpful, approachable, enthusiastic and intellectually very strong.”
    Recent work: Acted for HMRC in a Court of Appeal case over a group mismatch in derivative contracts.

    Michael Thomas
    Taxpayer-side practitioner with a broad-based advisory and contentious tax practice, spanning business tax, indirect taxes and private client matters. He is particularly well versed in property tax matters, including stamp duty, development matters and agricultural and business property relief from inheritance tax.
    Strengths: “Very thorough and sharp but practical, down to earth and easy to deal with.” “A creative and pragmatic tax counsel and a go-to choice for property tax issues of all descriptions.”
    Recent work: Acted on a pro bono case with the potential to set a number of important precedents. One of the issues concerned a tribunal’s right to determine time limits to reclaim overpaid tax.

    Richard Vallat
    Frequently acts for HMRC on challenges to avoidance schemes and is an expert on corporate tax and capital allowances issues. He takes instructions on the taxpayer side in cases concerning corporate tax schemes, employee benefit trusts and tax-related professional negligence. He also acts in contractual disputes.
    Strengths: “Calm and collected, with a good, practical, commercial take on everything.” “He is very succinct and persuasive, with sound legal analysis.”
    Recent work: Appeared in the Court of Appeal for HMRC in connection with a corporate tax scheme.

    David Yates
    Often appears unled against silks in cases for the Revenue, and also has a solid taxpayer-side practice. He advises on a broad range of matters including cross-border dividends and double taxation agreements. He has niche expertise in advising insurers on tax-related professional negligence matters.
    Strengths: “A diligent, bright and client-friendly barrister whose sector knowledge is second to none.” “Technically astute, very bright and very easy to work with.”
    Recent work: Acted for HMRC in connection with challenges to several important and high-value film finance schemes.

    Jeremy Woolf
    Senior junior with extensive experience in a range of complex corporate tax litigation and advisory mandates. He is particularly strong on income tax and employee benefit trusts issues.
    Strengths: “”He has a detailed knowledge of tax law and an ability to size up a situation and deliver relevant, pertinent advice.” “Very user-friendly.”
    Recent work: Junior counsel in John Mander Pension Trustees v HMRC before the Supreme Court, concerning the transfer of funds between pension schemes.

    James Henderson
    Junior counsel on some of the most significant corporate tax cases of recent years. He also has a thriving advisory practice, and receives regular instructions in cases regarding business reorganisations. He has sound knowledge of transfer pricing rules and capital allowances.
    Strengths: “His advice is very clear and very helpful.”
    Recent work: Acted in the FTT on behalf of the Revenue in a hearing concerning discovery assessment.

    Elizabeth Wilson
    Well-regarded junior who acts for both the taxpayer and the Revenue. Her corporate tax caseload spans a range of matters, from employment tax to SDLT.
    Strengths: “Really clever, really thorough and easy to talk to.”
    Recent work: Appeared in the Supreme Court for HMRC, a matter concerning the Shop Direct Group and corporate tax on overpaid VAT.

    Thomas Chacko
    Has developed an impressive and broad-ranging corporate tax practice. He has a growing reputation in employment tax matters. He also has experience of cases involving partnership structures.
    Strengths: “Practical, prompt efficient tax advice on the Tax Tribunal process.”
    Recent work: Acted for the appellant, J P Whitter, a family-owned company, in a Court of Appeal case concerning the renewal of its gross payment status.

    Zizhen Yang
    Appears with leading silks in major litigation and also handles her own cases unled. She has wide-ranging corporate tax expertise and has recently appeared in matters regarding double taxation relief, business reorganisations, loan relationships and derivative contracts.
    Strengths: “She is very precise in articulating submissions in writing and her oral advocacy is impressive.” “Very organised and unflappable.”
    Recent work: Acted in the Project Raindrop case, centred on how to construe Section 171 of the Tax of Chargeable Gains Act 1992.

    Tax:Indirect

    The Set: Pump Court Tax Chambers has a sizeable bench of practitioners skilled at dealing with high-profile tax matters. Members regularly act for both the taxpayer and the Revenue, and offer extensive expertise in VAT and other indirect taxes including insurance premium tax as well as customs and excise duty. The set also offers experience in specialist areas such as landfill tax and gaming duty. Sources highlight the “excellent range of skills” on offer in the chambers.

    Client service:“Senior clerk Nigel Jones and his team are fantastic, professional and very user-friendly.” “The clerks are friendly, accessible and commercial.”

    SILKS
    David Milne QC
    Highly praised by commentators who describe him as an “excellent advocate” and highlight his “winning manner with the court.” He has expertise in all areas of indirect tax, and is experienced in both complex advisory work and high-value litigation. He is frequently trusted with the most high-profile and substantial cases, and has represented clients before both the ECJ and the Supreme Court.
    Strengths: “”He is absolutely first class. One of the best silks for VAT work.” “His knowledge is near peerless and his experience is absolutely priceless.”
    Recent work: Represented the taxpayer in British Film Institute v HMRC, a case concerning the application of the EU cultural exemption for VAT on the price of cinema tickets.

    Andrew Hitchmough QC
    Regarded as a “go-to” silk, he is an indirect tax specialist who is highly praised by commentators as a particularly user-friendly barrister. He attracts attention for his vast expertise in the area and has represented the taxpayer and HMRC in some of the most high-profile VAT cases of recent years.
    Strengths: “He blends technically rigorous advice with commercial acumen and smooth client handling skills.” “He gets to the core of the matter quickly and impresses clients with his huge knowledge and practical approach.”
    Recent work: Represented the taxpayer in London Clubs Management v HMRC, an important gaming duty case.

    Kevin Prosser QC
    Head of chambers, he is lauded by market commentators as “extraordinarily good on his feet.” He continues to advise high-profile individuals and companies on complex direct and indirect tax issues stemming from corporate transactions. He is praised for his breadth of knowledge across the area.
    Strengths:  “A professional and eloquent barrister who excels in all tax matters. He is a master.” “He combines invaluable international law expertise with an incredible wealth of courtroom experience.”
    Recent work: Acted for the taxpayer in Wakefield College v HMRC, a case concerning whether the construction costs of a new building are zero-rated for VAT purposes.

    Rupert Baldry QC
    Described as a “very safe pair of hands,” he has a broad range of expertise in indirect tax, including customs and excise duties and aggregates levy. He undertakes advisory and litigation work for the Revenue and the taxpayer. He is particularly commended as “excellent on his feet.”
    Strengths: “He is insightful and clearly an expert in what he does.” “The master of the Aggregates Levy.”
    Recent work: Acted for the Revenue in Coin-A-Drink v HMRC, a case concerning the issue of whether EU law prevents the UK from taxing repayments of overpaid VAT.

    Julian Ghosh QC
    Maintains a broad practice encompassing all areas of tax, including indirect tax matters, in which he represents the taxpayer and the Revenue. He has particular expertise in EU tax matters and their crossover with UK tax legislation.
    Strengths:  “He is very clever, a brilliant litigator and fantastic at cross examination.”
    Recent work: Acted for the taxpayer in Leeds City Council v HMRC, a case concerning the three-year cap for VAT repayment claims.

    Roger Thomas QC
    Experienced practitioner who is highly praised for assisting charities with their indirect tax needs. He is very well versed in matters involving stamp duty land tax. He is lauded by market commentators as “very insightful and highly intelligent.” He is experienced in representing clients in both the Supreme Court and CJEU.
    Strengths: “He is very eloquent in court and he can make very complicated tax points seem simple.” “Extremely good on SDLT and VAT.”
    Recent work: Acted for the taxpayer in Zipvit v HMRC, a case concerning the VAT treatment of business supplies.

    JUNIORS
    Michael Thomas
    Upholds a broad tax practice, including business tax, VAT and private client work. Specialising in representing the taxpayer, he is noted for his particular expertise in property tax.
    Strengths: “Michael’s advice is pragmatic, well analysed and sensible.” “A practical and approachable barrister.”
    Recent work: Represented the taxpayer in Shields v HMRC, a case which raises questions about the operation of the UK’s flat-rate agricultural VAT scheme and whether it is contrary to EU law.

    Jeremy White
    Described by market commentators as “the go-to man for customs duties and excise work.” He also has vast knowledge of trade barriers, appearing regularly in the ECJ in cases involving numerous international customs authorities. He regularly acts for well-known multinational clients.
    Strengths: “He combines an encyclopaedic knowledge of customs rules and procedures with a unique willingness and patience to explain things to the non-customs specialist.” “He is sharp of mind, exceptionally intelligent and has a vast reservoir of technical knowledge.”
    Recent work: Acted for a consortium of seven appellants in a complex set of appeals concerning the classification of mobility scooters.

    Jonathan Bremner
    Considered a very able junior by market sources, he enjoys a rapidly growing practice in the area of indirect tax with extensive experience representing taxpayers and the Revenue. He is often entrusted with complex VAT and customs cases, appearing before the Supreme Court and the Upper Tribunal. He frequently appears unled across from QCs.
    Strengths: “He is very bright, he works very hard and he is a nice chap to deal with.” “He is very able and has a low-key style of advocacy.”
    Recent work: Acted as junior counsel for the taxpayer in Paul Newey t/a Ocean Finance v HMRC, a VAT case regarding exempt supplies and the alleged abuse of rights.

    James Henderson
    Offers an impressive indirect tax expertise within an overall tax practice. He is experienced in all areas of indirect tax, and is particularly well versed in complex VAT matters. He has experience acting for clients at all levels of domestic court, including the Supreme Court as well as appearing before the CJEU.
    Strengths: “Very responsive, thorough, thoughtful and well liked by clients.”
    Recent work: Acted as junior counsel for the taxpayer in Isle of Wight v HMRC, a case concerning the issue of whether local authorities must charge VAT on car parking charges.

    James Rivett
    Has a growing indirect tax practice with a particular expertise in VAT, often appearing before the Upper Tribunal. He attracts high praise from market commentators for his intelligence and litigation skills. He frequently acts as sole counsel or as a leader in tough cases.
    Strengths: “His preparation, legal analysis and court room manner as well as his general client-facing skills are exceptional.” “He is a very persuasive speaker.”
    Recent work: Acted as junior counsel for the taxpayer in Taylor Wimpey v HMRC, a case challenging the compatibility of the UK VAT regime with EU directives.

    Tax: Private Client

    THE SET: Pump Court Tax remains the foremost private client tax set in England and Wales. Barristers can assist on all types of matters, such as tax planning, trusts and estates, inheritance tax (IHT) and capital gains tax (CGT). Sources say it is “the best in town for tax work” and that “it has more of an emphasis on private client than any other of the sets.” One source comments: “They are our favourite chambers for tax. They really have moved with the times and have a very proactive, friendly and collaborative manner.” Other interviewees say it is “a first-rate chambers. They are a large set and cover everything that I need,” adding: “You know what you’re getting and that is top quality. They are brilliant at dealing with ultra-complex work and always get an efficient response.” One market insider adds: “There is a depth and breadth there that you can’t find anywhere else. So many members of the chambers have been involved in the leading tax cases.”

    Client service: “The clerks at Pump Court, led by Nigel Jones, are especially well regarded. One interviewee enthuses: “The clerks are all extremely helpful and easy to deal with. They are very responsive and user-friendly. I can’t think of a single instance when I haven’t been completely happy. They will always try to fit you in and make sure their barristers are delivering on time.”

    SILKS
    William Massey QC
    Best known for his private client work, with his expertise lying in trust and estate tax planning, business and agricultural property relief, heritage property and exemption. Massey’s work on complex trust and inheritance tax issues is especially noted.
    Strengths: “William is definitely frontline for IHT. When I’ve got William’s advice I will always take my time to read it carefully. He’s also very flexible, I can ring him whenever I need to and he’s always got time for the job because he’s innately interested in what he’s doing, and it shows.” “I always use him for complex matters. He is extremely thorough and learned but puts things into easily understandable language.”
    Recent work: Appeared in DC v AC, a Variation of Trusts Act case, where he succeeded in an application to extend the trust period to mitigate CGT and IHT liabilities.

    Kevin Prosser QC
    Prosser often acts on highly complex income tax and employee benefit trust (EBT) cases in the appellate courts. He also has experience on double taxation matters and sits as a deputy High Court judge.
    Strengths: “One of the best, if not the very best tax QC at the English Bar. He provides concise, technical advice in a very commercial, pragmatic manner.” “Outstanding and extraordinarily good on his feet. He is very responsive, razor sharp, and a very bright man.”
    Recent work: Acted for the taxpayer in Blackwell v HMRC, a CGT case concerning the deduction of fees against the gains from selling shares.

    David Ewart QC
    Highlighted for his work on behalf of the Revenue but also represents private clients in complex tax cases. He often advises on inheritance tax planning matters and family limited partnerships, and he has handled film finance scheme cases recently as well.
    Strengths:  “He’s very clever and technically impressive.” “Extremely practical, highly intelligent and very talented.”
    Recent work: Represented the taxpayer in an IHT case involving an excluded property trust settled by a non-domicile, who later became UK-domiciled and then left the country again. The key question was whether the property had lost its IHT-exempt status permanently or whether it had regained it after the taxpayer moved away again.

    Julian Ghosh QC
    Qualified to practise in both England and Scotland, with expertise in European taxation issues. Ghosh acts for HMRC and for taxpayers on a range of personal tax matters, and has particular expertise in Agricultural Property Relief (APR) and Business Property Relief (BPR) from IHT.
    Strengths: “Of all the barristers we’ve worked with, he’s the standout.” “Renowned for being technical and solid in his approach. He is a high-quality performer.”
    Recent work: Acted for the Revenue in the Rangers tax case. The former owners of the club made tax-free loans to staff and players from EBTs. The Supreme Court found that these payments ought to have been treated as taxable earnings for NIC and income tax purposes.

    JUNIORS
    Emma Chamberlain
    A supremely respected junior, with a huge reputation for her private client expertise. Specialises in tax and trust advice, particularly on offshore trust structures, for high net worth individuals.
    Strengths: “Remains the go-to person at the private client tax Bar. She has the ear of the HMRC and, where other barristers merely assert their opinion, she tells you what HMRC’s view really is.” “She is one of the best in the UK. She is very direct and you can really see the wood through the trees. She is very good at working through reams of complex detail and at co-ordinating all third parties, like lawyers and accountants, to work as a cohesive team.”
    Recent work: Represented the taxpayer in James Glyn v HMRC, a complex residence case.

    Elizabeth Wilson
    Practises in all areas of tax law. She has particular experience in APR and BPR cases, offshore trusts, partnerships and non-domiciliary tax planning.
    Strengths: “Very precise and clear in her advice.” “Highly technically competent, and has done some big cases for the Revenue.”
    Recent work: Appeared for the Revenue in Re Staveley Deceased, an Upper Tribunal IHT case.

    James Rivett
    Regarded by sources as a personable and impressive advocate who is in high demand. Rivett has particular expertise in the often arcane world of variation of trust, and he is also an expert in heritage property matters for landed estates.
    Strengths: “There doesn’t seem to be any aspect of tax that James Rivett hasn’t mastered. One always feels he is very much on your side in trying to find a solution without taking silly risks, but he doesn’t shirk the difficult message.” “He really knows what he is doing. He can translate sophisticated legal issues to the layman.”
    Recent work: Acted for the Revenue in Shiner & Sheinman v HMRC. At issue was the compatibility with EU personal rights of retrospective application of the closure of a tax loophole.

    Richard Vallat
    A highly regarded tax barrister, who specialises in advising on offshore trusts, domiciled issues and tax planning for ultra high net worth individuals.
    Strengths: “Highly competent and good at explaining complex matters in layman’s language.” “A formidable opponent. Charming outside court and very much fights his corner in court.”
    Recent work: Acted for HMRC in a conjoined income tax appeal before the Supreme Court, concerning the tax treatment of two complex employee share bonus schemes.

    Laura Poots
    Particular expertise in offshore trust and family partnership structuring and domicile matters.
    Strengths: “She’s a delight. She’s very much to the point, she’s clear, concise and makes things pretty easy.” “She is excellent on response times, and very knowledgeable on private client.”
    Recent work: Represented HMRC on personal tax issues related to an owner-managed property company.

    Ian Richards
    A highly regarded tax barrister, who specialises in advising on offshore trusts, domiciled issues and tax planning for ultra high net worth individuals.
    Strengths: “He’s very knowledgeable and careful, and drafts beautifully.”

  • Chambers & Partners HNW (2018)

    Pump Court Tax Chambers is widely regarded as the pre-eminent set for private client tax work at the London Bar. “It is second to none,” confirms an observer, while another market commentator says: “They continue to be the clear stand-out set for tax advice, you can rely on Pump Court to have specialists who are capable of dealing with every area of tax.” “As a chambers it is light years ahead of anyone else in terms of tax and has been way ahead for a long time,” comments a legal practitioner. Barristers at the set handle a wide range of litigious and advisory matters, which include offshore and onshore trusts, residence and domicile issues, Inheritance Tax and Capital Gains Tax.

    The set is lauded for its “very fine clerking team;” interviewees describe the team as “very friendly,” “efficient” and “always very prompt.” Senior clerk Nigel Jones is praised for “keeping a very orderly ship” and both Bruno Antoniotti and Rob Adams are noted by sources for the high level of service they provide.

    Emma Chamberlain “is a fantastic private client tax junior,” enthuses an interviewee. “I think she really is a superstar,” agrees a market insider. “Her particular expertise and skill is in the Inheritance Tax field and in non-domicile tax, which she is excellent at,” comments an observer, adding: “She is also ferociously intelligent.” “She has a real insight into how the Revenue think and so she brings a really interesting and helpful take on things,” says a barrister, adding: “She is not an aggressive advocate, but instead she is collaborative, which is winning for the judges because they will listen.” Another legal professional reports that “Emma’s ability to not just know the technical law, but to also know what HMRC is thinking from the inside is without equal.”

    William Massey QC “is the great star of the private client Tax Bar,” says a market insider, adding: “He has this reputation where people think if he thinks something, then it must be right.” “He has a good reputation for landed and heritage matters. He is just brilliant at relating to families and he can get to the nub of the matter really quickly; he is excellent and has been a great resource,” reports one interviewee. Another comments: “He has real gravitas, he’s very strong on Inheritance Tax, he’s very thoughtful and has a very rounded view.” Massey is also praised for his “technical abilities, charming manner, and his ability to explain complex points clearly.”

    The “seriously awesome” Kevin Prosser QC wins praise from all corners of the market for his tax expertise. “He is fabulous,” enthuses an interviewee, explaining that “he is forensic in his knowledge of the tax law but also creative. He finds the answers to the conundrum presented to him.” “I think he’s brilliant. He absorbs a huge amount of information and he can solve problems. He’s tremendously bright and always fits the bill – he’s been consistently excellent,” reports one source. Another comments: “He’s very much the leading light; I rate him very, very highly indeed, he’s an absolute star.” “He’s probably the best tax advocate there is,” says a fellow barrister.

    James Rivett is considered a “star at junior level” for his tax practice. He assists clients with advisory and contentious tax matters, including tax issues arising from divorces. An interviewee comments: “We love working with him – he is superb in person and verbally. If you want someone quick and to the point he is amazing; he has a very, very fast brain.” Rivett is also praised as “very bright and very engaging,” and “incredibly cerebral.”

    Elizabeth Wilson has a comprehensive litigation and advisory tax practice, which includes assisting with offshore trust planning and planning for non-domiciles. “She explained very tricky tax principles to the client in a way that they could really understand. She turned the papers around very quickly and her advice was spot-on,” reports one interviewee. Another agrees: “She is excellent on life insurance matters – she can understand it fully and make it easy to understand for the client. Her soft skills are excellent and she is very friendly and personable.”

    David Ewart QC is noted for his specialism in representing HMRC in tax cases. He also advises high net worth individuals on Inheritance Tax planning and trusts. “He is absolutely top class,” enthuses one interviewee. Another reports that “he’s a compelling advocate. He’s always in court, I do wonder how he has the time to prepare so well – whatever his secret is, it works.”

    Julian Ghosh QC is well respected for his tax expertise and frequently acts for both the taxpayer and HMRC. “He’s very clever, very hard-working and very knowledgeable,” comments a fellow barrister, adding: “I’m sure he’s very capable at anything he turns his hand to. He’s a very able person to have on your team.”

    Laura Poots is an experienced tax practitioner, assisting clients with tax planning matters as well as acting in litigation. “Her technical skills are first class, she’s very responsive, she tends to get the right answer and she’s commercial,” reports a source. “She’s very pragmatic and practical, lovely to deal with, very approachable and she takes the complexities out so you can really discuss things with her. She’s absolutely excellent, she’s my go-to person,” enthuses an interviewee.

    Richard Vallat QC is regularly instructed on offshore trusts and income tax matters. Vallat also has expertise in domiciliary issues and regularly represents HMRC in challenging tax planning schemes. “I have always found him to be extremely good on advisory matters,” reports one commentator. Another interviewee says: “He is very strong, very thorough, intelligent and user friendly.”

  • Chambers & Partners HNW (2017)

    Pump Court Tax remains the foremost private client tax set in England and Wales. Barristers can assist on all types of matters, such as tax planning, trusts and estates, Inheritance Tax and Capital Gains Tax. Sources say it is “the best in town for tax work” and that “they have more of an emphasis on private client than any other of the sets.” One source comments: “They are our favourite chambers for tax. They really have moved with the times and have a very proactive, friendly and collaborative manner.” Other interviewees say it is “a first-rate chambers. They are a large set and cover everything that I need,”adding: “You know what you’re getting and that is top quality. They are brilliant at dealing with ultra-complex work and always get an efficient response.” One market insider adds: “There is a depth and breadth there that you can’t find anywhere else. So many members of the chambers have been involved in the leading tax cases.”

    The clerks at Pump Court, led by Nigel Jones, are especially well regarded. One interviewee enthuses: “The clerks are all extremely helpful and easy to deal with. They are very responsive and user-friendly. I can’t think of a single instance when I haven’t been completely happy. They will always try to fit you in and make sure their barristers are delivering on time.”

    Silks

    Leading tax silk William Massey QC is best known for his private client work, with his expertise lying in trust and estate tax planning, Business and Agricultural Property Reliefs, heritage property and exemption. Massey is “understated but hugely impressive and he wears it lightly,” says an interviewee. Massey’s work on complex trust and Inheritance Tax (IHT) issues is especially noted. “William is definitely frontline for IHT,” states a source, “when I’ve got William’s advice, I will always take my time to read it carefully. He’s also very flexible, I can ring him whenever I need to and he’s always got time for the job because he’s innately interested in what he’s doing, and it shows.”

    Head of Chambers Kevin Prosser QC is “one of the best, if not the very best tax QC at the English Bar,” says a source. “He provides concise, technical advice in a very commercial, pragmatic manner.” Prosser is “extraordinarily good on his feet,” a source says, and another commenator adds: “He is very responsive, razor sharp and a very bright man.” Prosser often acts on highly complex income tax and employee benefit trust cases in the appellate courts. Interviewees say he “really can deal with the most complex issues and simplify them for the rest of us.”

    David Ewart QC is a highly regarded tax silk practising in all areas of taxation. He is highlighted for his work on behalf of the Revenue but he also represents private clients in complex tax cases. He often advises on inheritance tax planning matters and family limited partnerships, and he has handled film finance scheme cases recently as well. Sources say he has “a great reputation,” adding that “he’s very clever and technically impressive.”

    Julian Ghosh QC is qualified to practise in England and Wales and Scotland, with expertise in European taxation issues. Sources say his “ability to advise Scotland-based clients, particularly where trusts are involved, is invaluable,”adding: “His experience is excellent.” Ghosh acts for HMRC and for taxpayers on a range of personal tax matters, and has particular expertise in Agricultural Property Relief (APR) and Business Property Relief (BPR) from IHT. Ghosh is further praised as a “very good, clear, persuasive advocate,” and is “renowned for being technical and solid in his approach. He is a high-quality performer.”

    Juniors

    Emma Chamberlain is a supremely respected junior, with a huge reputation for her private client expertise. Chamberlain specialises in tax and trust advice, particularly on offshore trust structures, for high net worth individuals. She “remains the go-to person at the private client tax Bar,” says a source, adding: “She has the ear of HMRC and, where other barristers merely assert their opinion, she tells you what HMRC’s view really is.” Another says that Chamberlain “is one of the best in the UK. She is very direct and can really see the wood through the trees. She is very good at working through reams of complex detail and at co-ordinating all third parties, like lawyers and accountants, to work as a cohesive team.”

    James Rivett has an “excellent reputation in private client,” and is regarded by sources as a personable and impressive advocate who is in high demand. “There doesn’t seem to be any aspect of tax that James Rivett hasn’t mastered,” says a source, “one always feels he is very much on your side in trying to find a solution without taking silly risks, but he doesn’t shirk the difficult message.” Rivett has particular expertise in the often arcane world of variation of trust, and he is also an expert in heritage property matters for landed estates.

    Elizabeth Wilson practises in all areas of tax law. She has particular experience in APR and BPR cases, offshore trusts, partnerships and non-domiciliary tax planning. Sources say she is “very clever and very precise and clear in her advice.” A fellow tax barrister says Wilson is “highly technically competent, and has done some big cases for the Revenue.”

    Richard Vallat practises in all areas of revenue law and is especially well known for his private client work. Vallat is praised by a peer as a “formidable opponent,” who is “charming outside court and very much fights his corner in court.” Sources also say Vallat is “extremely pragmatic,” as well as being “highly competent and good at explaining complex matters in layman’s language.”

    Laura Poots has particular expertise in offshore trust and family partnership structuring and domicile matters. “She is always happy to discuss problems, responds very promptly and her advice is sound,” praises a source. Sources also report that her “written advice is clear and precise and a joy to read.”

    Ian Richards is a highly regarded tax barrister, who specialises in advising on offshore trusts, domiciled issues and tax planning for ultra high net worth individuals. One source says: “He’s very knowledgeable and careful, and drafts beautifully.”

  • Legal 500 (2017)

    THE SET: Demonstrating ‘unrivalled strength in depth’, Pump Court Tax Chambers is ‘undoubtedly the biggest and best tax set in London, with many eminent QCs and a huge array of talented juniors coming through’. In fact, for some, the juniors here are ‘the best at the Bar’.

    Client service: The clerks also provide ‘a first-class service’; they are ‘all extremely helpful and easy to deal with’, and ‘will always try to fit you in and make sure their barristers are delivering on time’. Senior clerk Nigel Jones is ‘superb’ and ‘the doyen of clerking’. Team leaders John Poyser and Bruno Antoniotti are also ‘very accomplished’.

    Tax: Corporate
    As the ‘strongest tax set by some margin’, Pump Court Tax Chambers is regularly instructed by the leading tax solicitors and thus continues to find itself involved in some of the most high-profile EU and UK tax cases. Several members were involved in the Franked Investment Income (FII) GLO appeal litigation, and Kevin Prosser QC and Richard Vallat appeared on opposite sides in UBS v HMRC, concerning the treatment of income tax on non-monetary company bonuses. The set is also ‘particularly strong on indirect tax issues’.

    David Milne QC – ‘Very well respected.’

    Kevin Prosser QC -‘He provides particularly impressive response times coupled with unmatched clarity.’

    David Ewart QC – ‘Deeply knowledgeable but with the flexibility to see both sides of an argument.’

    Julian Ghosh QC – ‘He thoroughly understands the line HMRC will take in court.’

    Rupert Baldry QC – ‘Quick on his feet and often much more polished than the opposition.’

    Giles Goodfellow QC – ‘A first-rate advocate with no perceptible weaknesses.’

    John Tallon QC –‘He has a sensible and relaxed manner that puts everyone at ease.’

    Roger Thomas QC – ‘Highly experienced and intellectually daring.’

    Jeremy Woolf – ‘Strikes a good rapport with judges and an absolute delight to work with.’

    Jonathan Bremner –  ‘One of the leading juniors at the Bar for high-stakes litigation.’

    James Henderson – ‘A bright, talented tax barrister with a vast wealth of knowledge.’

    Richard Vallat – ‘One of the best juniors at the tax Bar in terms of written work and court advocacy.’

    James Rivett – ‘An incisive barrister, who advances his views in a compelling manner.’

    David Yates – ‘Incisive in his analysis and concise in his advocacy.’

    Elizabeth Wilson – ‘Fiercely bright and tenacious with excellent commercial judgement.’

    Thomas Chacko – ‘Exceedingly bright and always on-the-ball of complicated tax issues.’

    Michael Thomas – ‘He brings a fresh approach for the benefit of all his clients.’

    Tax:VAT

    David Milne QC – ‘He develops a very good rapport with judges at the highest levels of court.’

    Kevin Prosser QC – ‘Highly strategic, with the courage to give the right advice even when it isn’t popular.’

    Rupert Baldry QC – ‘Technically astute, with a good bedside manner.’

    David Ewart QC – ‘He carries invaluable experience over a wide variety of cases.’

    Julian Ghosh QC – ‘Combines strong, technical analysis with good client skills.’

    Andrew Hitchmough QC –  ‘A straight-talking advocate, with a strong analytical mind.’

    Roger Thomas QC – ‘Ferociously bright, responsive and client-friendly.’

    Penny Hamilton -‘Dedicated, intelligent, commercial, approachable and liked by clients.’

    James Henderson – ‘Fantastic knowledge in the area combined with an easy manner.’

    Richard Vallat – ‘Very clear-thinking and known for explaining complicated tax issues in a lucid manner.’

    Jonathan Bremner – ‘Often instructed without a leader and perhaps an early candidate for silk.’

    Jeremy White – ‘Perhaps the doyen of customs duty advisers.’

    Jeremy Woolf – ‘Confident even in the most challenging court situations.’

    Michael Thomas – ‘Highly recommended for his capabilities in stamp tax and real estate-related tax litigation.’

    Sadiya Choudhury – ‘Incredibly knowledgeable and ready to break down complexity into understandable points.’

    Oliver Conolly – ‘Good in front of clients.’

    Thomas Chacko – ‘Hardworking and notably bright.’

    Zizhen Yang – ‘A tremendously hardworking junior, with strong drafting skills.’

    Private client: Personal Tax

    At Pump Court Tax Chambers, ‘one can be sure of getting the very best advice, at all levels’. The members are consistently involved in the most high-profile personal tax cases, such as appearing on both sides of the headline Rangers tax case; four members were involved, including Scottish-qualified Julian Ghosh QC, who secured a victory for HMRC in the Court of Session and then again in the appeal to the Supreme Court.

    William Massey QC – ‘Thoughtful and methodical; he identifies even issues that may not fall within his expertise.’

    Kevin Prosser QC – ‘A star of the tax Bar; one can rely on him completely in relation to any difficult matter.’

    David Ewart QC – ‘Extremely analytical and practiced at navigating the most complex provisions.’

    Julian Ghosh QC – ‘Always up to date on HMRC practices and attitudes.’

    Giles Goodfellow QC – ‘Inventive, yet practical, with a good understanding of client needs.’

    John Tallon QC – ‘Provides sensible and uncomplicated advice that can be understood by the layman.’

    Rupert Baldry QC – ‘Technically excellent, with impressive client skills.’

    Jeremy Woolf – ‘Exceedingly strong; he cannot be recommended highly enough.’

    Emma Chamberlain – ‘Pragmatic and very client-friendly.’

    Richard Vallat – ‘Good at distilling complex areas of law into understandable points.’

    Elizabeth Wilson – ‘Solution-oriented and methodical.’

    Laura Poots – ‘A talented junior, who provides clear and concise written advice.’

    Ian Richards – ‘He has very detailed knowledge on the taxation of non-domiciled taxpayers.’

    James Rivett – ‘There doesn’t seem to be any aspect of private client tax that he hasn’t mastered.’

    Thomas Chacko – ‘Very impressive; definitely one to watch for the future.’

    David Yates – ‘He gets to the core of the problem quickly and gives sensible, strategic advice.’

    Jan Matthews – ‘Clients appreciate his approachable and straightforward style.’

    Michael Thomas – ‘He is able to really get to the nub of the issue.’

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