The Set: Pump Court Tax Chambers “represents the very pinnacle of tax expertise,” and has some of the best tax counsel around at both silk and junior level. It is heavily involved in weighty income and corporate tax matters and high-profile avoidance cases, including those relating to film finance schemes. A significant number of the set’s silks and juniors are on the Treasury panels. “The set is made up of excellent individuals who are superbly well managed,” market commentators say.
Client service: “The clerks are always courteous and helpful.” Nigel Jones leads the team.
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. He regularly handles Supreme Court and ECJ briefs and wins praise for his strong advocacy in these tough cases.
Strengths: “An excellent advocate with a great mind. He has the ability to make the complex simple.”
Recent work: Acted for HMRC in its challenge to a tax scheme devised by EY and implemented by Greene King which involved loan relationship provisions.
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.
Strengths: “He’s so very quick to react, very responsive, very flexible and very proactive in giving advice. He is an experienced, leading silk with an amazing brain, who’s the ultimate failsafe option.” “A true heavyweight tax counsel whose opinions command respect and carry significant force.”
Recent work: Involved in an income tax case relating to shares given as part of a bonus. The key issue being whether shares counted as restricted shares for income tax purposes if the conditions under which they would be forfeited had been hedged against such that the recipient did not stand to lose out either way.
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.
Strengths: “His advice was clear, unequivocal and extremely helpful.”
Recent work: Represented HMRC in the Franked Investment Income GLO test case, concerning dividends paid into the UK by international subsidiaries of UK companies.
Julian Ghosh QC
Regularly appears before the highest courts both in England and Wales and in Scotland, acting for taxpayers and the Revenue. He is particularly well regarded for his work involving loan relationships and EU law.
Strengths: “Incredibly sharp. He’s client-friendly, switched on and practical.”
Recent work: Acted for HMRC in a corporate tax scheme case involving transfer pricing issues and the creation of an artificial loss on derivatives.
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 commercial and very forensic. His work is very, very impressive.”
Recent work: Acted for HMRC in defence of a group litigation challenge to the UK’s corporate manufactured overseas dividend scheme.
Giles Goodfellow QC
A “frighteningly clever” expert on income tax and employee benefits matters. He regularly provides advice on corporate reorganisations, tax-related professional negligence and tonnage tax.
Strengths: “Offers excellent, practical insights and has a first-rate knowledge of tax. Makes himself available at short notice.”
Recent work: Acted for the taxpayer in a case regarding the use of restricted shares in a subsidiary company to pay employees without incurring income tax or NIC liabilities. The value of the shares was realised on liquidation, which was not a chargeable event for tax purposes.
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.
Strengths: “Exceptionally intelligent and reassuringly confident advice.”
Recent work: Successfully appeared in the Supreme Court on behalf of the taxpayer in John Mander Pension Trustees v HMRC, a transfer of funds between pension schemes case.
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.
Strengths: “His approach is direct and straightforward – he sees the argument and presents it.”
Recent work: Acted for the taxpayer in a large-scale SDLT case concerning the acquisition of the Chelsea Barracks site.
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.
Strengths: “He is very, very bright. He is thoughtful, impressive, engaging and he shares things well. He always brings interesting things to the table.”
Recent work: Junior counsel in the Liberty tax scheme case.
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.
Strengths: “He has been extraordinary in terms of his kindness and patience. He also had a complete understanding of all aspects of the case.”
Recent work: Junior counsel in BT Pension Trustees v HMRC, a case concerning the tax treatment of dividend payments from shares in foreign companies.
Taxpayer-side practitioner with a broad-based advisory and contentious tax practice. He is particularly well versed in property tax matters, including stamp duty, development matters and agricultural and business property relief from inheritance tax.
Strengths: “A strong junior counsel with good all-round knowledge who gives strong commercial advice. He’s particularly strong on real estate-related tax matters.”
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.
Frequently acts for HMRC on challenges to avoidance schemes and is an expert on corporate tax and capital allowances issues. He also takes instructions on the taxpayer side in cases concerning corporate tax schemes, employee benefit trusts and tax-related professional negligence.
Strengths: “Leading junior, who is a lateral thinker with a commercial approach. He has excellent technical understanding.”
Recent work: Junior counsel on two conjoined appeals before the Supreme Court. At issue were schemes using supposedly restricted shares to pay employees free of income tax and NIC, where the circumstances under which the shares would be forfeited had been hedged against such that the employees could not lose out regardless.
Often appears unled against silks in cases for the Revenue, and also has a solid taxpayer-side practice. He has niche expertise in advising insurers on tax-related professional negligence matters.
Strengths: ” Easy to deal with, he gets into court and fights for his client.”
Recent work: Successfully represented HMRC in a case concerning the tax treatment of the taxpayer’s grant of an option over shares in a subsidiary company to an employee benefit trust.
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 is very client-friendly, almost impossibly nice and charming, and very tenacious. He will pull out all the stops and will work frighteningly hard to win.”
Recent work: Junior counsel in John Mander Pension Trustees v HMRC before the Supreme Court, concerning the transfer of funds between pension schemes.
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.
Strengths: “An authoritative advocate who prepares carefully and conscientiously for the case.”
Recent work: Junior counsel in Bristol & West v HMRC, a case concerning group mismatches in derivative contracts.
An “excellent” junior with a growing reputation in employment tax matters. He also has experience of cases involving partnership structures.
Recent work: Acted in Anson v HMRC, a Supreme Court appeal concerning double taxation relief on profits from a Delaware LLC.
Appears with leading silks in major litigation and also handles her own cases unled. She has recently appeared in matters regarding double taxation relief, business reorganisations and loan relationships and derivative contracts.
Strengths: “Industrious, user-friendly, and someone who produces outstanding drafting. She is well liked and highly regarded.”
Recent work: Acted in a transfer of assets between group companies case. The case turns on whether the paying off of a debt can be construed as a transfer of the debt to the creditor.
The Set: Pump Court Tax Chambers boasts an incredibly strong stable of experienced silks and juniors, contributing to its steadfast reputation as one of the leaders in this area. While members continue to be trusted with the largest VAT reclaim cases in the market, it also regularly receives challenging and high-profile briefs in areas such as landfill tax, gaming duty and VAT mitigation schemes.
Client service: “I have been impressed with the clerking service at Pump Court Tax Chambers. I have found the clerks to be friendly and approachable, as well as being efficient at keeping diary dates and facilitating conference calls.” “I have found Pump Court to be a very helpful set, dealing quickly with fee requests and assisting greatly with the preparation of court bundles.” The team is led by senior clerk Nigel Jones.
David Milne QC
Highly praised by commentators who describe him as “brilliant” and a “giant” of the Tax Bar. 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’s clearly one of the leading lights of the Tax Bar. He’s very good with clients and provides first-rate advice.” “He has an exceptional reputation.”
Recent work: Representing HMRC in an appeal regarding its challenge to a tax scheme devised by a high-profile professional services firm.
Andrew Hitchmough QC
An indirect tax specialist who is highly praised by commentators for his polished advocacy and user-friendly approach. 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’s a great orator, great in court, and he’s very skilled at putting across his arguments.”
Recent work: Acted for a group of trust companies in a case involving the supply of investment management services to investment trusts.
Kevin Prosser QC
Considered by market observers to be the “doyen of tax QCs,” 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 and depth of expertise across the area.
Strengths: “He has an ability to grasp the detail, but also his courtroom style is fantastic and his grasp of the arguments is unparalleled.” “He remains at the top of his game. The depth of his experience shines through when dealing with complex case strategy matters.”
Recent work: Acted for Mercedes-Benz in the Court of Appeal regarding whether the hire purchase of cars counts as supply of goods or services for the purposes of VAT.
Rupert Baldry QC
Described as a “thoughtful” and “understated” individual, he has a broad range of expertise in indirect tax, including customs, excise duties and aggregates levy. He undertakes advisory and litigation work for the Revenue and the taxpayer.
Strengths: “He approaches it as a team effort, which is great. He really involves his instructing solicitors so it’s a collaborative effort to get the right result.” “He is always careful to give that extra little bit of thought to something.”
Recent work: Assisted Hanson UK in a case relating to whether the movement of rocks within the construction site of a reservoir qualifies for aggregates levy.
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.
Strengths: “He is exceptionally bright.” “He brings an invaluable perspective to any case.”
Recent work: Represented Ocean Finance in the restructuring of its group to make it more VAT-efficient, which HMRC declared abusive.
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 being “a very balanced and cautious adviser, corrective to some of the other advisers who are out there.”
Strengths: “He was very impressive, and gave the client the clear steer that was needed. A masterful performance.”
Recent work: Acting in Longridge on the Thames v HMRC in a case questioning whether supplies made in relation to the construction of a training centre were zero-rated on the basis that the centre was intended for charitable purposes rather than business activities.
Maintains a broad tax practice, including business tax, VAT and private client work. Specialising in representing the taxpayer, he is particularly highly regarded by market commentators as “the go-to man for stamp duty land tax.”
Strengths: “Michael is an extremely articulate advocate and focuses on the key points in a case, narrowing the issues to ones which are winnable and most easily understood by the judge. When giving opinions, Michael is frank about the prospects and has usefully discouraged litigation in favour of dialogue with HMRC on a number of occasions, saving clients considerable costs and uncertainty.”
Recent work: Representing the taxpayer in Portland Gas Storage v HMRC, apropos the right to appeal a decision relating to stamp duty issues.
Enjoys an impressive indirect tax practice which includes vast experience in the climate change levy, customs and excise duties, aggregates levy and VAT. She attracts particular praise from market observers for her “authoritative” expertise in complex landfill tax matters.
Strengths: “She is competent, able and diligent.” “She is incredibly knowledgeable.”
Recent work: Acting for the taxpayer in Devon Waste Management Ltd v HMRC, a complex appeal concerning whether or not landfill tax should be paid on soft waste.
Considered to be an “extremely knowledgeable” individual, he is highly regarded by market commentators for his significant expertise in issues involving customs and duties. He also has vast knowledge of trade barriers, appearing regularly in the ECJ in cases involving numerous international customs authorities.
Strengths: “I am impressed by his vast retention of technical knowledge. Combined with his sharp mind and exceptional intelligence, he has the edge with customs matters.” “He was particularly easy to work with. He has a great deal of experience and knowledge in the niche area of customer international trade.”
Recent work: Acting for B&M Retail in the leading case relating to the burden of proof in connection with excise duty on spirits.
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.
Strengths: “He is very bright, able and personable.” “He’s very personable and certainly, in light of correspondence with him, he has an acute and forensic intelligence. He’s good on points of detail.”
Recent work: Represented PwC in a substantial VAT case considering which of two companies within a business group can bring a VAT claim.
Offers an impressive indirect tax practice within an overall tax expertise. He is experienced in all areas of indirect tax, and is particularly well versed in complex VAT matters.
Strengths: “He’s very smooth and straightforward in court. He puts across his case with great skill and simplicity.”
Recent work: Represented the taxpayer in a matter of overpaid VAT and failure to appeal within the time limit.
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.
Strengths: “He is very bright.” “He is an excellent litigator.”
Recent work: Represented the taxpayer in a case challenging the compatibility of the UK VAT regime with EU Directives.
Tax: Private Client
THE SET: Pump Court is a well-known personal tax and private client set that has particular expertise in offshore and onshore trust reorganisations and inheritance tax, and is a leader in employee benefit trusts. The team has experience of advising on entrepreneur’s, business property and agricultural property relief. Pump Court’s broad group consists of 22 barristers, eight of whom are silks.
Client service: “A leading set. The first people I would think of going to for private client tax. Beyond their expertise, the administration of the set is great; the clerks are very user-friendly and efficient. It’s a slick operation.” Nigel Jones is the head clerk.
William Massey QC
A leading silk in the Private Client Tax Bar, who is extremely experienced in a variety of areas, including tax and estate planning, agricultural property, BPR and APR. He has represented clients in the High Court and Supreme Court. He continues to grow his practice in matrimonial finance-related work.
Strengths: “Famously ‘the best in town’ when it comes to tax and landed estates.” “He is very masterful when it comes to dealing with the taxation issues affecting landed estates. To find a QC who can steer you around the law is absolutely essential, and Massey is one of the most capable landed estate tax barristers.”
Recent work: He provided beneficiaries with an opinion on the Variation of Trusts Act 1958 and successfully argued an extension of a trust period does not amount to a new settlement for tax purposes.
Kevin Prosser QC
His reputation and expertise lie in highly complex and litigious personal tax and income tax cases. He is increasingly representing individuals in cases relating to tax avoidance schemes.
Strengths: “Kevin is exceptional. His drafting is superb and he picks up points very quickly in conference.” “He is able to explain difficult concepts well, and is very persuasive. In addition to being very smart and knowing his way around tax, he gives practical guidance but can translate that convincingly and clearly in a court setting.”
Recent work: He represented UBS on an income tax issue relating to receiving shares in a company as bonuses.
David Ewart QC
As an accomplished private client tax practitioner, he advises clients on trust legislation, BPR and inheritance tax planning.
Strengths: “He is technically a superstar – pragmatic, thorough and imaginative.” “He is sensible, approachable, down-to-earth, low-key but clearly intelligent.”
Recent work: He represented Andrew Chappell, who claimed a deduction for overseas manufactured dividends which was challenged by HMRC.
Julian Ghosh QC
A QC in England and Scotland, he advises the taxpayer and Revenue on personal tax matters; he has a particular expertise in BPR and APR work.
Strengths: “He really is excellent, superb.”
Recent work: He represented a US LLC client on its right to not pay UK income tax on profits as a result of double tax relief.
Her practice focuses on private client tax, on matters such as trust reorganisation, the structuring of offshore trusts and companies, and IHT and CGT planning for UK-domiciled clients. Personal tax issues on divorce and employee benefit matters increasingly feature in her caseload.
Strengths: “She is the pre-eminent expert on all matters to do with tax of trusts and offshore trusts. She is top of the tree for that – an absolute star.” “She has extensive knowledge of the field and you know if you get an opinion from her, it’s going to be very difficult for the Revenue to argue against it.”
Recent work: Continued to represent a client in a residential dispute pertaining to time spent in Monaco.
Advises and litigates on IHT, CGT and offshore trust planning, and assists non-domiciliaries on planning matters. She also has experience of advising on tax-efficient investment vehicles such as partnerships and trust structures.
Recent work: Represented a client on the exemption of inheritance from IHT, and specifically argued the transaction was not a transfer of value.
An impressive personal tax junior, he advises HMRC and private client firms on tax issues, including innovative trusts techniques. He represents landed estates on BPR, APR and IHT matters.
Strengths: “I would swear by him. He can master the most arcane areas of tax law and create a road map of how you get from A to B. He is particularly good with non-domicile clients.” “We really appreciate how nimble he is. He takes it all in his stride. He’s really fantastic.”
Recent work: Relitigated the Shiner & Sheinman v HMRC case in the First-tier Tribunal, regarding retrospective application of UK legislation in relation to personal rights under EU law.
An experienced advocate advising clients on IHT, CGT, offshore trust estate planning and income tax matters. His practice sees him representing HMRC in alleged tax avoidance cases.
Strengths: “He is highly knowledgeable. He has the advantage that he understands the corporate side of things, so is a reliable pair of hands.” “He is completely charming outside court, and formidable as opposition once you cross through the door. He is clever and high quality – a strong tax litigator.”
Recent work: Represented HMRC on a late filing penalty relating to a self-assessment tax form. Successfully argued the wording in the form could be considered “proper notice.”
Focuses her practice on personal tax issues, including offshore tax structures and family partnerships aimed at minimising exposure to IHT, CGT and other taxes. She represents HMRC on tax issues with increasing regularity.
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.
Significant experience representing a broad range of private clients, including ultra high net worth individuals, international sporting individuals and entertainers. He assists his clients with residency status matters, offshore trusts and techniques to preserve and protect wealth and future gains.
THE SET: Pump Court Tax Chambers is ‘the pre-eminent tax set; its strength in depth is second to none’, and its barristers are ‘professional and understanding of client needs’.
Client service: The ‘top-notch’ clerks are ‘always able to direct solicitors to the appropriate counsel’. Nigel Jones ‘goes that extra mile to ensure a smooth process’ and is ‘integral to the success of chambers’. Team leader John Poyser and deputy team leader Rob Adams provide ‘good support’, and deputy team leader Bruno Antoniotti is another name to note.
Seen by many as ‘the top tax set in the country’, Pump Court Tax Chambers is ‘well run with a collaborative clerking team‘. On the direct tax front, Julian Ghosh QC is representing the Scottish government in a case regarding PAYE tax following Rangers FC’s collapse and rebirth; in indirect tax, it is ‘one of the stronger sets for dealing with customs and duties matters’.
David Milne QC – ‘A veteran of high-stakes cases.’
Kevin Prosser QC -‘A clear, concise and client-friendly adviser.’
David Ewart QC – ‘A track record of success on both sides of disputes.’
Julian Ghosh QC – ‘A superb litigator.’
Rupert Baldry QC – ‘He has an excellent mind and is a pleasure to work with.’
Giles Goodfellow QC – ‘A true outside-the-box thinker.’
Roger Thomas QC -‘He has an astute ability to align the tax position with the commercial issues.’
Jeremy Woolf – ‘A softly spoken yet heavyweight advocate.’
Jonathan Bremner – ‘A go-to junior for heavy-duty cases with significant technical content.’
James Henderson -‘An authoritative advocate, who prepares carefully for every case.’
Richard Vallat -‘A bright, talented tax barrister with a vast wealth of knowledge.’
David Yates -‘His legal analysis and advocacy are concise, incisive and persuasive.’
David Milne QC – ‘An excellent advocate demonstrating a good rapport with judges.’
Kevin Prosser QC -‘Never anything other than superb in his advice and in conference.’
Rupert Baldry QC – ‘Always in the frame for cases where you need a good technical leader.’
David Ewart QC – ‘Very good and very commercial’.
Julian Ghosh QC – ‘Valued for his sharp mind and ability to think around the issues’.
Andrew Hitchmough QC – ‘An excellent advocate, who has taken parts of indirect tax into whole new areas’.
Roger Thomas QC – ‘Very, very, very clever, and patient and friendly too’.
Penny Hamilton -‘Exceptionally good at making a complicated tax understandable for the lay client’.
James Henderson -‘An effective junior counsel’.
Richard Vallat -‘He has the ability to analyse facts clearly and quickly.’
Jonathan Bremner -‘‘Thorough, versatile and hardworking.’
Jeremy White -‘The master when it comes to excise duty issues.’
Jeremy Woolf -‘He always impresses with his sound, erudite, no-nonsense advocacy.’
Private client: Personal Tax
Pump Court Tax Chambers has ‘a wide range of barristers, all of whom are intellectually excellent’. William Massey QC successfully represented the taxpayer in Executors of Lord Howard of Henderskelfe v HMRC, in which the Court of Appeal found that an artwork was “plant” and therefore exempt from capital gains tax; the government ended that exemption subsequently.
William Massey QC – ‘A quietly persuasive advocate with unmatched expertise in trusts and heritage property.’
Kevin Prosser QC -‘First-rate, without the unattractive traits that can afflict some senior silks.’
David Ewart QC -‘He has built himself up a strong practice representing both HMRC and taxpayers.’
Julian Ghosh QC -‘Involved in some of the biggest and most controversial tax cases.’
Giles Goodfellow QC -‘Extremely technically able, but very approachable.’
John Tallon QC -‘He appears on both sides of challenging litigation.’
Jeremy Woolf – ‘He provides practical and helpful advice on international personal tax matters.’
Emma Chamberlain -‘She remains the absolute pinnacle of the private client tax Bar.’
Richard Vallat -‘He presents clear and succinct analysis that is practical and pragmatic.’
Elizabeth Wilson -‘Pleasant to deal with and very efficient’
Laura Poots -‘Very approachable and extremely knowledgeable’
Ian Richards -‘A lateral thinker with the ability to find solutions and add value’
James Rivett -‘His opinions are invariably detailed, well-researched and pragmatic.’
Thomas Chacko- ‘His work includes both high-profile litigation and complex advice.’
David Yates – ‘Extremely well regarded.’
Tax: Private Client: London
The pre-eminent private client tax set, Pump Court Tax Chambers has continued to consolidate its position as the top-rated chambers. One source praises the “collective wealth of knowledge at Pump Court Tax,” adding: “They are always very good, up to date and give sound advice.” Its members provide advice on landed estates, assisting with Business Property Relief (BPR), Agricultural Property Relief (APR) and Inheritance Tax (IHT) matters alongside acting on international cases involving offshore trusts.
Pump Court Tax is praised as “a class act at every level,” with “excellent technicians” throughout. Its members have been active on cases involving employment benefit trusts, income tax and film finance schemes. A source commends its “excellent and prompt service and sound advice.” “They are first-class: knowledgeable, respected and happy to work with you to find a solution for clients,” comments a market peer.
“Nigel Jones and his team of clerks are efficient and approachable,” reports one instructing solicitor. Jones, along with team leader John Poyser and deputy team leaders Rob Adams and Bruno Antoniotti, is described by another solicitor as “very good, straightforward on fees and good at keeping me informed.”
The “fantastic” and “first-class” William Massey QC is described by sources as “an absolute star” and praised for his”excellent grasp of tax planning issues.” An impressive practitioner, Massey enjoys a renowned private client tax practise with specific expertise in heritage and agricultural property. “William Massey is without challenge the highest regarded for landed estates and the leading tax QC for heritage matters,” lauds an interviewee. He has been instructed on some of the largest, most high-profile cases appears regularly before the Supreme Court and the High Court. “He is at the top of his game. He gives calm, measured and commercial advice: his understanding of the legislation is second to none.” Massey is also adept at handling cases involving BPR and APR, alongside matrimonial finance matters large complex Trust Act issues. “He is a real heavyweight. He is carved out a reputation in inheritance tax planning and particularly business assets requiring agricultural relief. He is very thoughtful, and is someone who thinks beyond tax and has good judgement,” comments a source.
Kevin Prosser QC is one of the most highly regarded and “standout” figures at the private client tax Bar. He has an unrivalled reputation for tax litigation and thus often appears on the leading, most high-profile personal tax cases. One source describes him as “simply superb,” adding: “He is particularly good at understanding what clients are trying to achieve. He stands in their shoes and gives incredibly practical advice.” Much of his work included Employment Benefit Trusts and income tax cases, and he often represents taxpayers in matters concerning alleged tax avoidance schemes. He is commended as “excellent, responsible, quick and user-friendly” with a “vibrant dynamic.” He is a Deputy High Court Judge and the author of Tax Appeals. Sources highlight his “very clear understanding of the tax legal position,” and describe him as “deeply knowledgeable and very helpful, with good judgement.”
David Ewart QC is a well-respected tax practitioner with a strong private client practise. He advises on all aspects of inheritance tax planning and assists on the structuring of wealth in family partnerships, offshore trusts and other vehicles. “He is always very clear in his advice, he has a good grasp of all the technicalities and possibilities, and doesn’t dwell on side issues that might not be relevant,” comments a source, He has also appeared on cases involving Accelerated Payment Notices and film finance schemes.
Julian Ghosh QC advises HMRC and high net worth taxpayers on a variety of private client tax matters. He is very experienced at handling matters concerning BPR and APR and regularly acts on cases involving capital gains tax, trust structures and employee incentive schemes. Sources praise his dual qualification, describing him as “an exceptionally bright QC who has the benefit of being qualified in both English and Scottish law.”
Emma Chamberlain “continues to impress” as the unrivalled junior barrister in the field. Sources praise her “razor-sharp tax skills” and “tremendous energy,” recognising her as “in a class of her own.” She is a noted expert on tax and trust matters and has substantial experience assisting on estate planning for high net worth private clients. “She is an expert at inheritance tax and trust work. She also has a background as a solicitor so has a very practical, hand-on approach. She will help you arrive at a solution rather than simply give you answers.” She divides her practice between IHT and Capital Gains Tax (CGT) planning for UK nationals, trust issues and other offshore matters affecting international clients. “She is extremely intelligent. She digs right down to the bottom of every issue, which is comforting when dealing with high-value, complex situations,” comments and interviewee.
The “very good” Elizabeth Wilson practices in all areas of personal tax advice and litigation. She has developed specific expertise in IHT, CGT and offshore planning for UK and non-UK domiciliaries and often advises on the use of partnerships and trusts as tax-efficient structures. “She is always efficient and thorough. Her advice is well thought through and she has a clear, profound understanding of many interrelated tax issues,” comments a market source.
Sources praise James Rivett as “a highly rated junior tax counsel who’s fiercely intelligent.” He regularly represents HMRC and works alongside leading private client law firms on some of the leading tax cases. He has developed a strong practice acting for owners of landed estates and is adept at handling matters involving offshore tax planning and matrimonial finance disputes. He is praised for his “very impressive” handling of cases, and described by interviewees as “clever, thorough and approachable.” “He is an impressive junior who is technically very good with an excellent manner,” says a market peer.
Richard Vallat is recognised for his “prompt technical advice” and skills as a “very good cross examiner.” With a practice that covers a range of personal tax planning advice and litigation, Vallat has established a considerable reputation for acting on IHT, CGT, estate planning and income tax issues. One source identifies him as his “first choice for most issues affecting the private client work,” adding: “He is always practical, both in terms of what works for the clients and what HMRC will accept.” Included in his broad practice is his knowledge of domiciliary issues, tax planning on divorce and business property relief on estates. “He is very able and practical when it comes to finding an appropriate solution particularly thorny issues. He understands HMRC’s view and is commercial and clear, which makes him client-friendly. A leading tax counsel of his generation and always a pleasure to work with,” says a marker peer.
Laura Poots provides “quality advice” according to her peers, she advises on all tax issues with a specific focus on private client and offshore structures such as trusts, family partnerships and LLPs. “She is very good, knows her stuff and is very responsive. Practical and savvy in her advice, she is also user-friendly and very bright.”
Ian Richards is a well-regarded non-contentious private client tax practitioner. He acts for international UHNW individuals, including billionaires, sports personalities and individuals from the entertainment and music sector. His practice encompasses offshore trusts, domicile and residence issues and wealth preservation. He is praised for being “very experienced in relation to owner managed businesses.”