Overview
Barbara is an experienced tax barrister who advises and acts across all areas of tax law including personal tax, corporate tax, VAT and other indirect taxes.
She is ranked a leading tax junior for corporate tax, indirect tax and private client tax in both Chambers UK Bar and Legal 500. She is also ranked for private client tax in Chambers HNW and Chambers Global. The directories note she is “absolutely terrific”, is “technically excellent” and provides “clear, powerful advocacy” whilst being “an absolute pleasure to work with – highly diligent, responsive and practical”.
As well as acting on her own account, she also frequently supports leading silks on significant, complex cases.
Barbara has experience in the context of settlement negotiations (including mediation) as well as appearing in tribunal and court. Barbara is Junior Counsel to the Crown – “A” panel.
Barbara is qualified to accept Public Access instructions.
A copy of Barbara's privacy notice can be found here.
Corporate tax
Barbara has acted in many of the high profile and important cases of recent years including:
- HMRC v Centrica Overseas Holdings Ltd [2024] UKSC 25: a Supreme Court decision concerning “expenses of management” for corporation tax purposes.
- Franked Investment Income (FII) GLO [2024] EWHC 195: concerns the taxation of dividends paid into the UK by foreign subsidiaries of UK companies and issues concerning limitation. High value litigation raising complex issues of EU law and restitution.
- HMRC v Altrad Services Ltd, Robert Wiseman & Sons Ltd [2024] EWCA Civ 720: important guidance from Court of Appeal on correct approach to the application of statute in the context of avoidance cases.
- HMRC v GE Financial Investments [2024] EWCA Civ 797: concerned whether the taxpayer was entitled to a credit against UK corporation tax for tax that the taxpayer paid in the USA. Significant to both treaty interpretation and as to the effect of share stapling.
- HMRC v Fisher [2023] UKSC 44, a case concerning the scope of the important anti-avoidance legislation on ‘transfers of assets abroad’.
- Embiricos v HMRC [2022] EWCA Civ 3 a case concerning the circumstances in which HMRC can be required to issue a “partial” closure notice.
- Inmarsat Global Ltd v HMRC [2022] EWCA Civ 1076 a case concerning capital allowances on satellite launch costs.
Indirect tax
Recent cases:
- Gray & Farrar International LLP v HMRC [2023] EWCA Civ 12: important guidance on the classification of VAT supplies.
- SilverDoor v HMRC [2024] UKUT 147 (TCC): guidance as to the characterisation of VAT supplies and the intermediary services exemption.
- VAT exemption relating to “management” of special investment funds.
Personal tax
Recent cases:
- Lefort v HMRC [2024] UKFTT 926 (TC): whether a taxpayer could rely on Fixed Protection 2014 in relation to a pension where the strict conditions had been breached, allegedly by mistake.
- Laker v HMRC [2024] UKFTT 568 (TC): notable case on statutory construction in the context of the NHS Pension Scheme Regulations (1995/300).
- Grint v HMRC [2024] UKFTT 956: significant case in relation to the “sales of occupation” anti-avoidance provisions.
- HMRC v Fisher [2023] UKSC 44, a case concerning the scope of the important anti-avoidance legislation on ‘transfers of assets abroad’.
- Embiricos v HMRC [2022] EWCA Civ 3 a case concerning the circumstances in which HMRC can be required to issue a “partial” closure notice.
Directory recommendations
Chambers UK Bar
Tax: Corporate Tax
Ranking: Band 1
- “Absolutely terrific” and “really thorough in her research.”
- “Extremely clever and someone who masters complex transactions and legal issues quickly and efficiently.”
- “She’s a demon when it comes to cases with complicated facts and difficult tax issues.”
- “She has a very analytical approach, and is responsive and a pleasure to work with.”
- “She’s an exceptionally strong junior.”
Tax: Indirect Tax
Ranking: Band 2
- “Bright, diligent and good on the evidence.”
- “She is technically excellent and a fantastic speaker who displays great attention to detail.”
- “Always gets to the heart of a matter and has deep insight into the case.”
Tax: Private Client Tax
Ranking: Band 2
- “Barbara is modest but quietly brilliant; she wrestles with a problem until she finds the answer.“
- “She is very clever, has a good client manner, can lower tension levels and is a great writer.”
- “Barbara Belgrano is formidably intelligent, eloquent and excellent at formulating and communicating arguments. She has been an inspiring and thoughtful leader.”
The Legal 500
Tax: VAT
Ranking: Leading Junior, Tier 2
- “An exceptionally bright and able junior. She has huge technical ability, a terrific eye for detail, drafts with precision and is exceptionally diligent and focused. She is everything that one would wish to see in a junior barrister.”
- “Barbara’s attention to detail is amazing. She is exceptionally strong technically. I admire her work ethic. She goes out of her way to ensure clients feel like they are in safe hands.”
Tax: Corporate
Ranking: Leading Junior, Tier 2
- “An absolute pleasure to work with. She is highly diligent, responsive and practical.”
- “Her legal knowledge and reasoning abilities are exceptional. Clear, powerful advocacy.”
- “Barbara is an excellent barrister. She has a strong, confident advocacy style and an excellent client manner. Very hard working. Insightful analysis. A real team player. Responsive and user-friendly. A pleasure to work with.”
Tax: Personal
Ranking: Leading Junior, Tier 2
- “Barbara is an absolute pleasure to work with. She is highly diligent, responsive and practical.”
- “Barbara is fiercely clever, conscientious and robust in her advice.”
Chambers High Net Worth
Tax: Private Client
Ranking: Leading Junior, Band 1
- “Barbara Belgrano is so impressive. She is formidably intelligent as well as being friendly and thoughtful.”
- “Barbara Belgrano is formidably intelligent, eloquent and excellent at formulating and communicating arguments.”
- “Barbara is modest but quietly brilliant; she gets a problem and wrestles with it until she finds the answer. She is very clever, has a good client manner, can lower tension levels and a great writer.”
- “Barbara Belgrano has strong technical knowledge and is very responsive.”
Chambers Global
Private Wealth: Tax (Bar)
Ranking: Band 2
Barbara Belgrano is a highly regarded tax junior with a broad practice in Revenue work.
- “Barbara is modest but quietly brilliant; she wrestles with a problem until she finds the answer. She is very clever, has a good client manner, can lower tension levels and is a great writer.”
- “Barbara Belgrano is formidably intelligent, eloquent and excellent at formulating and communicating arguments. She has been an inspiring and thoughtful leader.”
- “Barbara Belgrano has strong technical knowledge and is very responsive.”
Professional memberships
Revenue Bar Association
COMBAR
Career & education
2006-2010: University of Cambridge, Downing College: BA in English and French Law (Double Maîtrise)
2010-2011: Kaplan Law School: Bar Professional Training Course