Overview
Charles Bradley’s practice is evenly split between litigation and advisory work, principally focused on direct tax. He is on the Attorney-General’s ‘B’ panel of junior counsel but represents both taxpayers and HMRC. He is editor (with Emma Chamberlain) of Dymond’s Capital Taxes.
A copy of Charles Bradley's privacy notice can be found here.
Corporate tax
Recent work includes:
Representing the taxpayer (a multi-national corporation) in a dispute about the loan relationship ‘unallowable purpose’ provisions.
Representing HMRC in a case about an EBT scheme, which is expected to be the first decided case on the GAAR.
JRO Griffiths Ltd v RCC [2021] UKFTT 257 (TC) (FTT): represented the taxpayer, the leading supplier of potatoes to Walkers Crisps, in an appeal on the question of whether a potato store was ‘plant’ for capital allowances purposes.
E.On UK plc v RCC [2021] SFTD 1107 (FTT): represented HMRC in a dispute about the taxability of payments to employees in the context of changes to defined benefit pension schemes.
RCC v Smith & Nephew Overseas [2020] 1 WLR 2770 (Court of Appeal): represented the taxpayer (led by Julian Ghosh QC and Jonathan Bremner QC) in a case about forex losses.
Indirect tax
Recent work includes:
Advising a major law firm on place of supply of legal services for VAT purposes.
Alpha State Apparels Ltd v RCC [2019] UKFTT 644 (TC) (FTT): represented HMRC in a customs duty appeal about ‘buying commission’.
Simplyhealth Group Ltd v RCC (2018, FTT): represented the taxpayer (with Julian Ghosh QC and Quinlan Windle) in a dispute about whether certain rebates fell within art 90 of the Principal VAT Directive.
Rokit Ltd v RCC [2017] UKFTT 447 (TC) (FTT): represented the taxpayer, a well-known vintage clothing shop, in a customs dispute as to whether its imports qualified as ‘worn clothing’.
Pensions tax
Recent work includes:
Harrison (deceased) v RCC [2021] STC 2338 (Upper Tribunal): represented HMRC in a case about the tribunal’s jurisdiction on an appeal against refusal to accept late application for fixed protection.
Ketley v RCC [2021] STC 1932 (Upper Tribunal): represented HMRC in an appeal concerning ‘reasonable excuse’ in the context of late applications for enhanced protection.
RCC v Sippchoice Ltd [2020] STC 1331 (Upper Tribunal): represented HMRC in a case deciding whether pensions tax relief was available on ‘in specie’ contributions to pension schemes.
RCC v Bella Figura Ltd [2020] STC 922 (Upper Tribunal): represented HMRC in an appeal about HMRC’s powers to assess scheme administrators to scheme sanction charges.
Private Client
Recent work includes:
Advising on a multi-million pound residence dispute.
Representing the taxpayer in a ‘lead case’ on inheritance tax home loan schemes.
Khan v RCC [2022] 1 WLR 539 (Court of Appeal): represented HMRC in a case concerning the application of the ‘Ramsay’ approach to income tax on company distributions.
RCC v Tooth [2021] 1 WLR 2811 (Supreme Court): represented the taxpayer (led by Julian Ghosh QC) in the leading case on ‘discovery’ assessments.
Wilkinson v RCC [2020] SFTD 1077 (FTT): represented HMRC in a ‘lead case’ on the taxability of compensation for mis-selling of interest-rate hedging products.
Memberships
- Revenue Bar Association
- London Common Law & Commercial Bar Association
Career & education
- Called 2010 (Lincoln’s Inn)
- 2009-10 Bar Vocational Course (BPP)
- 2008-09 Graduate Diploma in Law (City University)
- 2003-06 MA History (St Catharine’s College, Cambridge)