Undoubtedly the biggest and best tax set in London.

Legal 500, 2018

  • Chambers Global

    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

    Tax

    Pre-eminent set with a deep bench of barristers who act for and against the Revenue and have key roles in a host of leading cases. Cases concerning the full spectrum of corporate taxes are undertaken and members are expert in such areas as tax schemes, advance payment notices, double taxation treaties, diverted profits tax and employee benefit trusts. Recent cases include Ingenious Film Partners v HMRC, which involved a large film finance scheme, and Glencore Energy UK v HMRC, a high-profile diverted profits tax case.

    Client service: Nigel Jones, the senior clerk, provides a fantastic service and is very good at finding availability for counsel and agreeing fees quickly.” “The clerking is excellent. Nigel Jones is very, very helpful; he’s always available, he’s highly responsive and he’s always willing to help.”

    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. Thornhill has additional knowledge relating to tax schemes, capital gains tax and Advanced Payment Notices.
    Strengths: “He’s a go-to member of the Bar particularly in relation to the tax implications of employment structures.”
    Recent work: Acted for the taxpayers in Daarasp LLP & Betex LLP v HMRC, which concerned a tax avoidance scheme to generate sideways loss relief for investors.

    Barbara Belgrano
    Accomplished junior experienced in a wide range of complex corporate tax cases. She acts for the taxpayer and HMRC in cases involving tax schemes, double tax treaties and group litigations relating to the taxation of dividends.
    Strengths: “Extremely clever and someone who masters complex transactions and legal issues quickly and efficiently.” “She’s an exceptionally strong junior.”
    Recent work: Acted for the taxpayer in Inmarsat plc v HMRC, a matter concerning the capital allowances code and the launch of telecommunications satellites.

    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. Ewart has undertaken an interesting selection of matters including those concerning film finance schemes, double tax treaties and corporate restructurings.
    Strengths: “Hugely knowledgeable and able to deal with complex issues simply and persuasively.”
    Recent work: Acted for the Revenue in the important Supreme Court case of Prudential v HMRC (Dividends and CFC GLO).The matter concerned the taxation of dividends paid into the UK by foreign subsidiaries of UK companies. It was established that the taxpayer was not entitled to compound interest on wrongfully-levied advance corporation tax, merely simple interest.

    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 sides. He acts for both the taxpayer and the Revenue. His advisory practice includes assisting with high-profile M&A transactions and reorganisations. He regularly handles Supreme Court and ECJ briefs.
    Strengths: “Incredibly good and incredibly bright.” “He’s a very, very experienced tax QC and a very strong advocate who knows the technical tax issues inside out.”
    Recent work: Acted for the taxpayer in Ingenious Film Partners v HMRC, a case concerning a large film finance scheme.

    David Yates QC
    Highly regarded barrister who acts for the taxpayer and HMRC in a broad range of cases including significant group litigation orders. He advises on matters including cross-border dividends and double taxation agreements, and has niche expertise in advising insurers on tax-related professional negligence matters.
    Strengths: “A leader in his field, who is incredibly knowledgeable and excellent to work with.” “His advice and all-round approach are top-notch.
    Recent work: Acted for the Revenue in a group litigation challenge to the UK’s manufactured overseas dividend scheme.

    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 capital gains tax. She is experienced in handling cases that touch on EU law.
    Strengths: “She has a very wide area of expertise and provides comprehensive advice in an easy-to-follow manner.”
    Recent work: Acted for the Revenue in Travel Document Service and Ladbroke Group International v HMRC, a Court of Appeal case concerning a loan relationship tax scheme.

    Giles Goodfellow QC 
    An expert on income tax and employee benefits matters, who regularly provides advice on corporate reorganisations, tax-related professional negligence and tax schemes. He acts for both the Revenue and taxpayers, and is noted for his knowledge of the Managed Service Company legislation.
    Strengths: “Always able to find good practical solutions to difficulties, he is very user-friendly and gets to the heart of the problem directly.” “He provides insightful analysis.”
    Recent work: Acted for the taxpayer in Haworth v HMRC, which concerned HMRC’s issuance of follower notices in connection with a ‘Round the World’ tax scheme.

    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. Henderson has sound knowledge of transfer pricing and the diverted profits tax rules.
    Strengths: “Very responsive, thorough and thoughtful. Clients find him very easy to work with.”
    Recent work: Acted for the Revenue in two cases concerning taxpayers’ gifting of shares to charities.

    James Rivett QC
    Has a broad-based corporate tax practice and regularly appears in major cases relating to matters such as tax schemes, double tax treaties and manufactured overseas dividends. He represents both the Revenue and the taxpayer.
    Strengths: “Extremely good and very persuasive.” “He’s very enthusiastic and super bright.”
    Recent work: Acted for the Revenue in Smith & Nephew v HMRC, a case concerning the taxation of loan relationships.

    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, corporate restructuring and employee benefit trusts issues. Woolf is also knowledgeable about judicial reviews and tax-related human rights matters.
    Strengths: “He is multi-skilled; he’s very thorough, highly approachable and someone with a wide repertoire in tax.”

    Jonathan Bremner QC
    Boasts an impressive track record of acting in heavyweight litigation, and is often instructed in major EU law cases and group litigations. He also advises in relation to double tax treaties, the taxation of dividends and other matters.
    Strengths: “Ferociously intelligent, enormously hard-working and very assured on his feet.” “He’s a very meticulous and very clever tax lawyer.”
    Recent work: Acted for the taxpayer in Smith & Nephew v HMRC, a case concerning the taxation of loan relationships.

    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 tax schemes and the taxation of intellectual property, among other issues.
    Strengths: “A fine technical thinker and a good courtroom advocate,” “he provides incisive, precise and crystal-clear advice.”
    Recent work: Acted for the taxpayer in Smith & Nephew v HMRC, a matter concerning the taxation of loan relationships.

    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 the diverted profits tax and transfer pricing.
    Strengths: “His judgement and ability to structure an argument before tribunal are terrific.” “He is an absolutely outstanding advocate.”
    Recent work: Acted for the taxpayer in Inmarsat plc v HMRC, a case concerning the capital allowances code and the launch of telecommunications satellites.

    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, and is an expert on corporate tax and tax treaties. Thomas is notable for the fact that during his first 13 years at the Bar he did not lose a case for either a taxpayer or any party to a civil claim where he had conduct at first instance.
    Strengths: “Collaborative and solution-driven,” “he is a creative, hands-on barrister who is both an excellent draftsman and advocate.”
    Recent work: Acted in Raftopoulou v HMRC, a tax reclaim dispute.

    Richard Vallat QC
    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: “Articulate, concise, persuasive in his advocacy and very effective.” “He’s a very bright, technically able, strong advocate.”
    Recent work: Acted for the Revenue in Inmarsat plc v HMRC, a case looking at the capital allowances code and the launch of telecommunications satellites.

    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 and SDRT cases. He acts for a diverse set of clients including accountants, City firms, museums and political parties.
    Strengths: “Provides extremely practical, high-quality, complex advice.”
    Recent work: Acted for the taxpayer in W A Tinkler v HMRC, which investigated whether the Revenue had properly opened an inquiry into the taxpayer’s tax returns.

    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, double taxation treaties and the taxation of foreign dividends.
    Strengths: “A persuasive and immensely eloquent advocate.” “He’s very commercial and pragmatic.”
    Recent work: Acted for the Revenue in Gallaher plc v HMRC, which looked at the differences between UK and EU tax law in the area of capital gains tax.

    Thomas Chacko
    Has developed an impressive and broad-ranging corporate tax practice. He has a growing reputation in employment tax matters, and has experience of cases involving partnership structures.
    Strengths: “Diligent, responsive and very easy to work with.” “He has an encyclopaedic knowledge of the law.”
    Recent work: Acted for the taxpayer in Bayonet Ventures LLP and Ronald Keith Howard v HMRC, a matter concerning how pensions legislation interacts with LLP regulations.

    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 appeared in matters regarding tax schemes, business reorganisations, loan relationships and derivative contracts. She acts for both HMRC and the taxpayer.
    Strengths: “Creative and very, very good with technical arguments, she comes up with things that other people haven’t really identified.”
    Recent work: Acted in Brain Disorders v HMRC, a tax scheme case concerning the investment of money in treatments for scientific research into psychological disorders.

    Tax: Indirect

    Leading tax set with a large bench of practitioners covering the full spectrum of indirect tax matters. Members act for and against the taxpayer and have notable expertise in cases relating to VAT, landfill tax, gaming duty, SDLT and customs and excise duties. Recent matters undertaken by the set include Wakefield College v HMRC, which concerned the treatment of VAT on construction costs, and ‘Project Blue’, which examined the acquisition of the Chelsea Barracks site and associated SDLT exemptions. Sources comment: “If you look at this chambers it’s like a Who’s Who of the tax world.”

    Client service: “Nigel Jones, the senior clerk, is fantastic as he’s very commercial and very sensible to deal with.” “The set has a great team of clerks who are highly responsive.”

    Andrew Hitchmough QC
    An indirect tax specialist who attracts attention for his vast expertise in the area. He has represented the taxpayer and HMRC in some of the most high-profile VAT cases of recent years. Hitchmough also has knowledge of the laws surrounding other indirect taxes such as gaming duty, and is noted for excelling in cases that involve banking and accounting law.
    Strengths: “A first-class, go-to silk who’s very well reasoned and a pleasure to deal with.” “He’s a very effective advocate and his drafting is very, very clear and very elegant.”
    Recent work: Acted for the taxpayer in London Clubs Management v HMRC, a case concerning gaming duty on free bets.

    David Milne QC
    An excellent advocate whose indirect tax practice includes 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. He has impressive knowledge of the EU’s VAT regulations.
    Strengths: “Provides excellent, top-quality advice.” “He has great insight and knowledge and is really effective.”
    Recent work: Acted for the taxpayer in A N Checker Ltd v HMRC, a VAT case that tested two conflicting principles of EU law.

    David Yates QC
    Acts for both the taxpayer and HMRC on a broad range of indirect tax mandates including those relating to stamp duty and landfill tax. He is further adept at handling matters involving VAT and customs and excise duties.
    Strengths: “A very good advocate who is always well prepared and able to think quickly on his feet.”
    Recent work: Acted for the Revenue in Jazztel v HMRC, which dealt with the alleged incompatibility of features of the UK’s stamp duty regime with European legislation.

    James Henderson
    Offers impressive indirect tax expertise within his overall broad tax practice. Although experienced in all areas of indirect tax, he is particularly well versed in complex VAT matters. Henderson has experience of acting for clients at all levels domestically, including the Supreme Court, and has also appeared before the CJEU.
    Strengths: “He gives clear views in a remarkably quick time and is very collaborative.”

    James Rivett QC
    Has a growing indirect tax practice with a particular expertise in VAT, and often appears before the Upper Tribunal. He acts for the taxpayer in leading cases and is often called upon to advise on extremely complex matters.
    Strengths: “He’s super user-friendly and very able.” “Hugely clever and a brilliant advocate.”
    Recent work: Acted for the taxpayer in Anglian Water v HMRC, a high-value claim for overpaid VAT

    Jeremy White
    A specialist in customs duties and excise cases who is particularly experienced in the classification of goods. He 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: “The expert on customs duty matters,” “he brings a rich level of technical detail to his cases.”
    Recent work: Acted for a consortium of seven appellants in HMRC v Invamed Group Ltd and Others, a customs classification case concerning mobility scooters.

    Jonathan Bremner QC
    Has a rapidly growing indirect tax practice and extensive experience of representing taxpayers and the Revenue. He is often entrusted with complex VAT, SDLT and customs cases, and has appeared before the FTT, the Upper Tribunal, the Supreme Court and the CJEU.
    Strengths: “Responsive, coherent and clear in his advice.”
    Recent work: Acted for the Revenue in Hannover Leasing v HMRC, an SDLT dispute concerning partnerships and unit trusts.

    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, and has acted in a number of VAT reclaim cases.
    Strengths: “A very thorough advocate” who is “very, very bright.”
    Recent work: Acted for the taxpayer in Simply Health v HMRC, a case concerning the VAT treatment of systems used to pay for dental services.

    Kevin Prosser QC
    Head of chambers, who advises 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 VAT, input tax and zero-rating, among other areas. Prosser often conducts appellate advocacy in the highest UK and EU courts, and is noted for the highly effective advice he dispenses to corporations.
    Strengths: “Really effective and excellent at getting to the nub of the issue – he just brings the court along with him.” “A very, very powerful advocate.”
    Recent work: Acted for the taxpayer in Wakefield College v HMRC, a case concerning the treatment of VAT on construction costs.

    Laura Poots
    A rising junior with wide experience of advising the taxpayer and the Revenue in indirect tax cases. She is particularly noted for her expertise in VAT, and has handled a number of cases involving the exemption for special investment funds.
    Strengths: “Very able and comprehensive in her approach.” “She does a very, very good job.”
    Recent work: Acted in BlackRock Investment Management v HMRC, an important case on the electronic supply of fund management services and the scope of the exemption for Special Investment Funds (SIFs) under the EU VAT Directive.

    Michael Thomas
    Has a broad tax practice that takes in business tax, VAT and private client work. Specialising in representing the taxpayer, he is noted for his particular expertise in property tax.
    Strengths: “Practical and has an impressive knowledge of real estate taxation, particularly SDLT.” “He has a brilliant mind and really cares about the outcome.”
    Recent work: Acted for the taxpayer in Shields & Sons Partnership v HMRC, which looked at the operation of the UK’s flat rate agricultural VAT scheme.

    Richard Vallat QC
    Regularly advises and acts for companies in a number of significant indirect tax matters. He is deeply experienced in complex VAT and stamp duty cases.
    Strengths: “A brilliant lawyer who knows SDLT like the back of his hand.” “He is particularly good on VAT and film finance issues and is a genuine expert on all tax-related matters.”
    Recent work: Acted for the taxpayer in Serpentine Trust v HMRC, which examined whether benefits under supporter schemes were liable for output tax at the standard rate.

    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, and is experienced in representing clients in both the Supreme Court and CJEU. He often acts in major VAT cases involving input tax and zero-rating.
    Strengths: “Very good indeed and brilliant in court, he’s a very effective performer.”
    Recent work: Acted for the taxpayer in Zipvit v HMRC, a case looking at the VAT treatment of business supplies.

    Rupert Baldry QC
    Has a broad range of expertise in indirect tax matters, including those relating to VAT, stamp duty, customs and excise duties and the aggregates levy. He undertakes advisory and litigation work both for the Revenue and the taxpayer.
    Strengths: “A particularly clever VAT lawyer.” “He explains things well and his advice is very easy to understand.”
    Recent work: Acted for the Revenue in Jazztel v HMRC, which centred on the alleged incompatibility of features of the UK’s stamp duty regime with European legislation.

    Zizhen Yang
    A junior with experience across indirect tax, who has particular strength in VAT and landfill tax cases. She frequently represents the taxpayer in a variety of high-profile cases.
    Strengths: “Her preparation is impressive, her analytical skills are top-rate and she’s a very thoughtful advocate.” “She is phenomenally hard-working, possesses very good drafting skills and is enormously responsive.”
    Recent work: Acted for two of the three appellants in Devon Waste Management Ltd and Biffa v HMRC, a landfill tax appeal concerning the ‘fluff’ layers in landfill sites.

    Tax: Private Client

    Pump Court Tax Chambers is widely recognised as the foremost set in the private client tax market. One source says: “It is a supremely well-run chambers stuffed to the gunwales with talented barristers offering superior expertise.” “It always provides the best in terms of knowledge and capability.” The set tackles the full range of taxation matters, and regularly advises on such areas as residence and domicile, IHT and CGT planning, trust reorganisation and employee benefit trusts. Members have recently been heavily involved in cases concerning film finance schemes and the requirement to correct tax due on offshore assets, and have also seen an increase in instructions relating to tax issues in complex matrimonial finance cases.

    Client service: “The clerks are always practical and efficient, and nothing is too much trouble for them.” “They are always very well co-ordinated.” Nigel Jones is the senior clerk.

    David Ewart QC
    Regarded for his work in both contentious and non-contentious matters, he is instructed by both taxpayers and the Revenue. He is sought after for inheritance tax work and other highly complex issues.
    Strengths: “Enormously helpful and turns things around at great speed.” “He has the ability to get to the nub of the issue even when the case is extremely complicated. David gives practical advice that the client understands.”
    Recent work: Acted in Excalibur (Kerrison v HMRC), a case concerning a complex tax scheme.

    David Yates QC
    New silk with a strong reputation at the Tax Bar. He is known for his detailed approach and is regularly instructed both by taxpayers and by HMRC.
    Strengths: “Very detailed in his approach and good on technical points.”
    Recent work: Acted for the Revenue in Routier & Venables v HMRC, a case concerning IHT in the context of charitable giving. The deceased, Mrs Coulter, provided in her will for certain bequests, and then stated that the residue should be put into a trust for certain stated charitable purposes. The executors assumed that this residue was free from IHT, a stance with which HMRC disagreed.

    Elizabeth Wilson
    Highly respected junior with a broad and successful private client tax practice. She is noted for her work for HMRC, but also frequently represents taxpayers. She has particular experience in APR and BPR cases, offshore trusts, partnerships and non-domiciliary tax planning.
    Strengths: “User-friendly and very approachable.” “She has a very nice, calm and controlled manner about her.”
    Recent work: Acted in HMRC v Parry & Others, a case concerning core principles of inheritance tax and especially the scope of exemptions from IHT. In particular, the case concerned the application of Sections 3 and 10 of the Inheritance Tax Act 1984, and what it meant for a transaction not to be a transfer of value because of there being no gratuitous intent.

    Emma Chamberlain
    An exceptionally well-known and highly respected tax junior with an impressive reputation for her handling of tax and trust advice. She is a particularly fine choice of counsel for offshore matters and is regularly trusted by high net worth individuals. Such is her standing that she was recently awarded an OBE for ‘services to government tax policy’.
    Strengths: “The go-to person for technical advice on trusts and tax” and “simply the best in the private client sector.” “When positions are uncertain she has the ability to sit down and get matters agreed with the revenue. She really goes in to bat for you.”
    Recent work: Acted in James Glyn v HMRC, a highly complex residence case.

    James Rivett QC
    Recently elevated to silk, he is 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: “An absolute star on the tax advisory side, he is so in demand these days that it would be helpful if he were cloned.”
    Recent work: Instructed for the Revenue in R (on the application of Jimenez) v the FTT and HMRC, a case brought by an individual resident in Dubai who had been issued with a notice to provide information to HMRC. He claimed that the revenue has no right to issue such notices to people in other jurisdictions.

    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 and Business Property Relief from inheritance tax.
    Strengths: “A technically exceptional barrister who clients like because he is always very confident. He is very balanced in his views and is someone who listens to and engages with those that instruct him.”
    Recent work: Instructed by the taxpayer in a case concerning the rules of personal tax assessment. The taxpayer, Raymond Tooth, had participated in a failed avoidance scheme, and subsequently HMRC had made a discovery assessment, which had established an inaccuracy in his return and an insufficiency of tax.

    Kevin Prosser QC
    Often acts in the most highly complex and high-value matters across the full scope of private client tax work. He appears in income tax and employee benefit trust cases in the appellate courts, and also has experience in double taxation matters. Prosser sits as a deputy High Court judge.
    Strengths: “Outstanding and a clear market leader. He is an excellent barrister who is very commercial, which clients like.” “A very accomplished barrister who is very calm in his approach.”
    Recent work: Instructed in Morrisons Trust v HMRC, a case concerning the structuring of offshore trusts.

    Laura Poots
    Has particular expertise in offshore trust and family partnership structuring and domicile matters.
    Strengths: “An excellent junior for complex tax cases who can hold her own arguing with QCs.” “Incredibly user-friendly, she’s the type of person you can pick the phone up and have a chat to.”
    Recent work: Acted in Cyclops Electronics and Graceland Fixing v HMRC, a case concerning companies that had undertaken a series of transactions that resulted in employees receiving loan notes carrying certain restrictions, enabling them to benefit from exemptions from income tax. HMRC argued that these transactions obliged Cyclops and Graceland to account for national insurance contributions and to pay income tax under the PAYE system.

    Richard Vallat QC
    Practises in all areas of private client tax work, with a particular emphasis on offshore trusts, tax planning and cross-border and domicile issues. He is regularly sought after by high net worth individuals.
    Strengths: “Offers excellent advice and knowledge when it comes to cases concerning estates with offshore trust and tax aspects.” “Approachable and very practical.”
    Recent work: Acted in Ingenious Film Partners v HMRC, a case concerning a large tax scheme devised by a major firm of accountants involving £700 million of tax relating to well over £1 billion of film finance transactions.

    William Massey QC
    Exceptionally well-known and highly respected silk with a commanding reputation at the Tax Bar. He is sought after for the most complex and high-value work, including planning, trusts and estate matters.
    Strengths: “Very measured and very good with clients.” “He’s utterly reliable, superb with clients and commercial as well as technically excellent.” “William Massey really knows his stuff.”
    Recent work: Acted for The Sunderland Foundation and Justine Markovitz in Gelber v The Sunderland Foundation & Others, a case concerning the powers of trustees, in particular those trustees of private family trusts looking to make a distribution to a charity that is not a beneficiary of the trust.

    Professional Negligence

    David Yates QC
    Has a niche specialism in tax and finance-focused professional negligence claims, which is greatly enhanced by his former career as a corporate financial analyst. He has advised on a wide range of financial claims relating to film finance schemes and offshore trusts, as well as faulty tax, accountancy and legal advice. He is often sought out by defendant insurers.
    Strengths: “He’s extremely cool-headed and rational.” “A diligent, bright and client-friendly barrister whose sector knowledge is second to none.”

     

  • Chambers & Partners HNW

    Pump Court Tax has the deepest bench of private client tax practitioners at the Bar. “They are the undisputed biggest and best set,” says a fellow barrister; “they have the depth in numbers, and they’re very good people.” Another interviewee says: “The set includes barristers with a very wide range of skill sets and a good number with very strong reputations.”

    The clerking team is led by Nigel Jones“Clerking has always been efficient and friendly,” a source reports; “they don’t put up barriers between us and the barristers but are genuinely part of the team. They work seamlessly in the background to make things work, particularly Nigel Jones.”

    David Ewart QC acts for the Revenue on tax cases and for high net worth individuals in IHT planning. An instructing solicitor says Ewart “has the ability to get to the nub of the issue even when it is very complicated, and he gives practical advice the client understands at the end of it. He’s also relatively easy to engage with – which is one of the reasons you want to instruct someone.” Fellow counsel say he is “a scary advocate to be against  – he doesn’t let things go, he is very tenacious.”

    David Yates QC took silk in 2019. A solicitor says Yates’s strengths are his “exceptional knowledge and strong recall of case law and statute,” reports that he is “always very well prepared for conferences,” is “very quick-thinking and impressive on his feet,” and that “you never have any doubt about the correctness of his instincts.” “His real skill is preparation,” says a fellow barrister, adding: “He knows every document backwards – he will know the exact line that you wish your client hadn’t written and he will centre on it.”

    Elizabeth Wilson often acts for HMRC, but she also assists with offshore trust planning and work involving non-domiciles. A peer says Wilson is “brilliant – rightly in Band One – she is super good, a really precise thinker.” Another adds that, in a recent matter, “she was sensible and we were able to have a forthright, reasonable exchange of views.”

    Emma Chamberlain is a standout senior junior with a spectacular reputation for complex tax matters. “If I had to name one tax barrister who has an ironclad knowledge of her subject, it would be Emma,” says an instructing solicitor, adding: “Emma literally wrote the book on the issues on which we instructed her, and her working knowledge of how HMRC is responding at any given point in time is incredibly useful. Her relationship with them also lends her opinions an additional weight, in my view.”

    James Rivett QC took silk in 2019, and remains a popular choice among private practice solicitors and with the Revenue for tax advisory work and litigation. Fellow counsel says he is “very thorough, very personable, good with clients and an effective advocate.” An instructing solicitor considers Rivett “an absolute star on the tax advisory side, but in such demand these days it would be helpful if he could be cloned.”

    Julian Ghosh QC works for the Revenue and for taxpayers, often on critically important tax cases. “He is a technically exceptional barrister and always very confident, which is very suitable for the clients,”says an instructing solicitor, who adds: “I like working with him because he listens and engages with you, and recognises that we have expertise and skills too.”

    Kevin Prosser QC is highly praised for the quality of his advocacy. “He is great,” says a barrister, who explains that “he is a very compelling advocate – he will be jumping up and down taking every point for his client, he will fight like a boxer. He manages to turn a case around with his skill as an advocate. He is also spellbinding in the way he lectures.” Another source says: “He is a first-rate advocate. If you are arguing with him, you have to be prepared for a fight.”

    Laura Poots is often instructed by HMRC, and has been appointed to the Treasury B panel for this work. She also takes instructions on the taxpayer side, and instructing solicitors in private practice consider her to be “incredibly user-friendly” and “an excellent junior – one of our go-to juniors for complex tax.”

    Richard Vallat QC is often instructed on tax scheme cases, including the enormous and hugely significant Ingenious Film Partners case. His practice has gone from strength to strength since taking silk in 2018. A source says Vallat’s strongest points are “a very practical approach and the ability to explain this both to other professionals and to clients.” This source adds that “he is particularly impressive in conference in listening to all the input and questions from the clients.”

    William Massey QC is hugely well respected for Inheritance Tax matters, particularly concerning landed estates and heritage property. Fellow counsel says Massey is “very smooth and persuasive – it is a pleasure to listen to him. He’s very effective.” Another barrister describes him as being “well established as a high-calibre performer – top of the range.”

  • Legal 500

    ‘The best set in the country for tricky tax issues and disputes’, Pump Court Tax Chambers’ list of barristers ‘reads as a “Who’s Who” of the tax world’. With its very broad offering it is, for some, the ‘go-to’ set to deal with all tax issues as well as associated private client matters. ‘They have some really good young barristers and cover all tax bases at all levels of experience,’ said one source, with another adding: ‘I have never had any difficulty with availability because of the set’s strength in depth at every level.’ The clerking team is ‘always helpful and keen to make sure the right barrister for the advice needed’. ‘First-rate’ senior clerk Nigel Jones manages ‘a well-run ship’ which also includes team leaders John Poyser and Bruno Antoniotti, who are ‘always very responsive’.

    Private client: personal tax

    Private client: personal tax – Leading sets – ranked: tier 1

    The ‘pre-eminent tax set‘, Pump Court Tax Chambers’ list of barristers ‘reads like a “Who’s Who” of the tax world’. Chambers is ‘the leading set’ for personal tax issues, according to clients, who also highlight how it is a ‘very well-run set of chambers with first-class expertise’. The set handles the full range of work from onshore trust re-organisations to advice on residence and domicile issues. William Massey QC acted for The Sunderland Foundation and Justine Markovitz (the first and second defendants) in a widely discussed case which considered the powers of trustees of private family trusts. In another case of note, appearing in the Court of Appeal, Kevin Prosser QC secured a successful outcome for the revenue in Brain Disorders Research LP v HMRC, a case that considered a scheme that had been set up to enhance capital allowances and interest relief.

    Private client: personal tax – Leading silks

    Kevin Prosser QC‘Is superb – he solves problems with incredible speed’ Ranked: tier 1

    William Massey QC‘Is the top UK inheritance tax barrister; you dread the day that he retires’ Ranked: tier 1

    David Ewart QC – ‘Has a practical and logical approach to solving problems’ Ranked: tier 2

    Giles Goodfellow QC -‘Is imaginative and finds solutions that others have not spotted’ Ranked: tier 2

    John Tallon QC‘Explains things in plain English and sees both sides of a problem’ Ranked: tier 2

    Julian Ghosh QC ‘A formidable intellect combined with his own style of forthright and succinct advocacy has generated a reputation as one of the leading tax silks’ Ranked: tier 2

    Rupert Baldry QC‘Is user-friendly, pragmatic and sharp’ Ranked: tier 2

    Private client: personal tax – 2018 silks

    Jonathan Bremner QC ‘Provides you with clear advice’ Ranked: tier 1

    Richard Vallat QC –  ‘Personable, pragmatic and finds solutions’ Ranked: tier 1

    Private client: personal tax – 2019 silks

    David Yates QC‘An exceptionally clear and user-friendly barrister, with a very practical approach’ Ranked: tier 1

    James Rivett QC‘Explains complicated matters very well’ Ranked: tier 1

    Private client: personal tax – Leading juniors

    Emma Chamberlain – ‘Has a superb understanding of HMRC’s thinking and likelihood of challenge; strong technical knowledge, commercial and practical-minded advice’ Ranked: tier 1

    Elizabeth Wilson‘A very reassuring presence, bringing calm and clear advice’  Ranked: tier 2

    Ian Richards – ‘As well as an acute knowledge of complex tax issues – particularly those involving offshore taxation issues – he has a very commercial mindset’ Ranked: tier 3

    Jeremy Woolf –  ‘A highly recommended junior’  Ranked: tier 3

    Jan Matthews‘A very well-regarded junior barrister’ Ranked: tier 3

    Laura Poots – ‘Puts things into plain English’ Ranked: tier 3

    Thomas Chacko –  ‘Immensely bright and very responsive’ Ranked: tier 3

    Professional negligence

    Professional Negligence – 2019 Silk

    David Yates ‘Very technical and precise’  Ranked: tier 1

    Tax: corporate and VAT/indirect tax

    Tax: VAT – Leading sets – ranked: Tier 1 

    Tax: corporate and VAT/indirect tax – Leading sets – ranked: tier 1

    Pump Court Tax Chambers is the ‘number one set for tax in terms of strength in depth, areas of specialism, and quality of counsel‘, and has ‘many stars and excellent, commercial clerks who manage client relationships well‘. Members are consistently involved in high-profile group litigations, most recently including FII GLO, a test case challenging the UK’s legislation on the taxation of dividends paid into the UK by foreign subsidiaries of UK companies (David Ewart QC and Rupert Baldry QC acted for HMRC with Jonathan Bremner QC on the other side); and MODS Group Litigation, a challenge to the UK’s Corporate Manufactured Overseas Dividend Scheme, where Baldry QC was instructed by the Revenue. In 2019, David Yates QC and James Rivett QC took silk, adding to an already strong selection of Queen’s Counsel in chambers, including David Milne QC, who has ‘a very good rapport with judges‘, and ‘class-act‘ Kevin Prosser QC. The ‘enormously impressive‘ Zizhen Yang is a junior of note, currently representing the taxpayer in its landfill tax appeal before the Upper Tier Tax Tribunal in Devon Waste Management Ltd and Biffa v HMRC.

    Tax: VAT – Leading silks

    Andrew Hitchmough QC‘Pre-eminent VAT advocate whose strength lies in his ability to articulate a point with utmost clarity and to distill the key issues to win even the most complex of cases’ Ranked: tier 1

    David Milne QC‘Very good rapport with judges particularly at the higher levels’ Ranked: tier 1

    David Ewart QC‘Incredibly broad practice and possesses in-depth experience on most tax issues; huge technical ability’ Ranked: tier 2

    Kevin Prosser QC – ‘Impressive at testing issues and ensuring that all aspects of an issue are understood; responsive’ Ranked: tier 2

    Julian Ghosh QC – ‘A go-to expert for issues involving the interaction of tax rules that turn on accounting treatment’ Ranked: tier 3

    Rupert Baldry QC – ‘He is a joy to work with and clients love his pragmatic straightforward advice’ Ranked: tier 3

    Roger Thomas QC‘He produces work of a very high standard’ Ranked: tier 4

    Tax: corporate – Leading silks

    David Milne QC‘Very good rapport with judges particularly at the higher levels’ Ranked: tier 1

    Julian Ghosh QC ‘A go-to expert for issues involving the interaction of tax rules that turn on accounting treatment’ Ranked: tier 1

    Kevin Prosser QC – ‘Impressive at testing issues and ensuring that all aspects of an issue are understood; responsive’ Ranked: tier 1

    David Ewart QC ‘Incredibly broad practice and possesses in-depth experience on most tax issues; huge technical ability’ Ranked: tier 2

    Giles Goodfellow QC‘He is wise and approaches matters with a broad perspective’ Ranked: tier 3

    John Tallon QC‘Very approachable and sees all sides of a problem’ Ranked: tier 3

    Roger Thomas QC – ‘He produces work of a very high standard’ Ranked: tier 3

    Rupert Baldry QC‘He is a joy to work with and clients love his pragmatic straightforward advice’ Ranked: tier 3

    Tax: VAT – 2018 Silks

    Jonathan Bremner QC – ‘Brilliant technical mind, strong common sense, admirable and experienced advocate’ Ranked: tier 1

    Richard Vallat QC – ‘He has immense clarity of thinking and presents a clear and succinct legal analysis, which is also practical and pragmatic’ Ranked: tier 1

    Tax: VAT – 2019 Silks

    David Yates QC‘He provides clear, accurate and timely advice and is an excellent courtroom advocate’ Ranked: tier 1

    Tax: corporate – 2018 Silks

    Richard Vallat QC – ‘He has immense clarity of thinking and presents a clear and succinct legal analysis, which is also practical and pragmatic’ Ranked: tier 1

    Tax: corporate – 2019 Silks 

    David Yates QC‘He provides clear, accurate and timely advice and is an excellent courtroom advocate’  Ranked: tier 1 

    James Rivett QC – ‘He is tenacious and argues his cases convincingly’ Ranked: tier 1

    Tax: VAT – Leading juniors

    James Henderson – ‘He is noted for VAT and customs duty expertise’ Ranked: tier 2

    Zizhen Yang – ‘She impresses enormously with her incredible capacity to produce high-quality documents and arguments in a very short time’ Ranked: tier

    Jeremy Woolf ‘In court he is a softly spoken yet heavyweight advocate, who always impresses with his sound, erudite no-nonsense submissionsRanked: tier 3

    Jeremy White – ’He has mastered the ability to articulate multi-layered issues to clients clearly; providing concise robust advice to keep clients both safe and commercially viable’ Ranked: tier 3

    Laura Poots – ‘A great junior on complex matters, makes a strong contribution to the technical analysis of cases’  Ranked: tier 3

    Oliver Conolly‘Knowledgeable in all areas of tax law’ Ranked: tier 3

    Sadiya Choudhury – ‘Her willingness to assist with complex problems, often at short notice, makes her of invaluable assistance in any tax dispute’ Ranked: tier 3

    Thomas Chacko – ‘Incredibly sharp, incisive and alive to the commerciality of the tax position for the client’ Ranked: tier 3

    Tax: corporate – Leading juniors

    Jeremy Woolf ‘In court he is a softly spoken yet heavyweight advocate, who always impresses with his sound, erudite no-nonsense submissions’ Ranked: tier 1

    Elizabeth Wilson – ‘She is an excellent junior counsel’ Ranked: tier 2

    James Henderson ‘He is noted for VAT and customs duty expertise’ Ranked: tier 2

    Thomas Chacko –  ‘Incredibly sharp, incisive and alive to the commerciality of the tax position for the client’ Ranked: tier 2

    Zizhen Yang‘She impresses enormously with her incredible capacity to produce high-quality documents and arguments in a very short time’ Ranked: tier 2

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