Overview
Arthur joined Chambers as a full tenant in October 2024 after completing his twelve-month pupillage. He has a broad practice across all areas of Chambers’ expertise, with a particular focus on private client tax. He is also regularly instructed in litigation matters, having appeared (including both led and unled cases) in the First-tier Tribunal, Upper Tribunal and Court of Appeal.
In addition to the above, Arthur also accepts instructions in all areas of personal and corporate tax as well as chancery, company, public law and professional negligence matters with a substantial tax element. Arthur is qualified to accept instructions under the Public Access scheme.
A copy of Arthur’s privacy notice can be found here.
Private Client Tax
Arthur has developed a significant private client advisory practice including advising on:
- Inheritance tax including family home planning.
- Taxation of trusts (onshore and offshore).
- Rectification and rescission claims.
- Agricultural and business property relief.
- The 2025 and 2026 changes to the taxation of non-domiciliaries and inheritance tax.
- Residence and domicile.
He is also regularly instructed in litigation matters touching on private client taxes, including:
- Acting for the successful Defendants in R (Martin) v The Chancellor [2026] EWHC 1123 (Admin) (led by Mark Fell KC), one of the most significant tax-related judicial review claims in recent years concerning the reforms to agricultural and business property relief.
- Acting successfully for HMRC in Tower One St George Wharf v HMRC [2025] EWCA Civ 1588 (led by James Henderson), a leading case on the scope and application of the targeted anti-avoidance rule for stamp duty land tax (s75A Finance Act 2003).
Recent advisory work includes:
- Advising the settlor of an offshore trust on the application of the transfer of assets, settlements and capital gains anti-avoidance legislation.
- Advising trustees on the tax implications of trustee borrowing and charging trust property in favour of the settlor and beneficiaries.
- Advising individuals on the availability of business property relief for shares settled into trust.
- Considering the residence position of internationally mobile individuals and reviewing the tax implications (including under double taxation treaties) across all major taxes.
- Considering the characterisation of foreign entities including a foreign partnership and usufruct.
Corporate and Employment Tax
Arthur has a considerable amount of experience in corporate and employment taxes, including with corporate restructurings, employee remuneration and share schemes. In particular, he has been involved extensively in matters concerning the treatment and scope of earnings, including redirected and disguised remuneration.
Arthur is experienced in advising on schemes of reorganisation involving UK and non-UK companies (and UK and non-UK shareholders), including on the application of:
- The share exchange provisions and associated elections and anti-avoidance rules.
- Substantial shareholding exemption.
- Loan to participators charge.
- CGT degrouping charge.
- Unallowable purpose rule.
- Transactions in securities.
- Relevant anti-avoidance purpose/motive tests.
Recent work on employment taxes include:
- Advising on the income tax implications of proposed lump sum payments made to former employees and steps to de-risk the tax position.
- Advising on an earnings charge for payments routed through EFRBS.
- Considering the correct income tax treatment of lump sum payments from overseas pension schemes including the application of the disguised remuneration provisions and treaty relief.
- Advising on the availability of tax deduction for expenditures under both the wholly and exclusively rule and for specific categories of expense.
VAT, SDLT and Indirect Taxes
Arthur’s indirect tax practice spans all areas of VAT and SDLT. Recent cases include:
- Acting for the taxpayer (led by Quinlan Windle) in their successful appeal against a VAT determination in Performance Leads v HMRC [2025] UKFTT 660 (TC), which concerned the application of the financial intermediaries VAT exemption to a lead generation business.
- Acting successfully for HMRC in Tower One St George Wharf v HMRC [2025] EWCA Civ 1588 (led by James Henderson), a leading case on the scope and application of the targeted anti-avoidance rule for stamp duty land tax (s75A Finance Act 2003).
Arthur has also advised on matters involving SDLT, including on the application of various reliefs and exemptions and on the general SDLT anti-avoidance rule, including on land held in trust or in corporate structures.
For VAT, he has advised on the characterisation of supplies, the nature of indivisible or ancillary supplies, and the availability of exemption or zero rating.
Public Law
Arthur has developed a notable public law practice in judicial review proceedings with a tax element. Recent work includes:
- Acting for the successful Defendants (led by Mark Fell KC) in R (Martin) v The Chancellor [2026] EWHC 1123 (Admin), one of the most significant tax-related judicial review claims in recent years concerning the adequacy of the consultation exercise undertaken prior to the introduction of reforms to agricultural and business property relief.
- Representing HMRC and HM Treasury (led by Sadiya Choudhury KC), successfully resisting an application for permission to bring judicial review in a human rights challenge against IHT provisions.
Professional negligence
Arthur is regularly instructed to advise on tax aspects of civil claims and in claims involving negligent tax advice. Recent examples include:
- Advising on the tax loss associated with a putatively wrongful transfer of properties out of a deceased’s estate, including considering the current and counterfactual tax position across IHT, CGT and SDLT.
- Advising on the limitation position on a potential claim against advisors where the tax consequences of the incorrect advice did not materialise until a later stage, including the application of the fraud, concealment or mistake exception.
- Considering the merits of a professional negligence claim where advisors had failed to warn the lay clients of adverse tax consequences.
Education
- 2022 – 2023 – City, University of London – BVS (Distinction)
- 2021 – 2022 – Keble College, University of Oxford – BCL (Distinction)
- 2018-2021 – Lady Margaret Hall, University of Oxford – BA Jurisprudence (First Class)
Memberships
Revenue Bar Association
Languages
- English
- Cantonese
- Mandarin
Awards
Scholarships & Prizes
- 2022 – Queen Mother’s Scholarship – Middle Temple
- 2021 – Roger Lui Keble College Scholarship – Keble College, Oxford
- 2021 – White & Case Prize in Company Law – Oxford Law Faculty
- 2020 – Slessenger-Brierly Prize – Lady Margaret Hall, Oxford
- 2020 – Dame Barbara Mills Prize – Lady Margaret Hall, Oxford
