Overview
Josh accepts instructions in all areas of Chambers’ practice, including business taxation, private client matters, international tax, and environmental taxation.
Josh has extensive experience in the sphere of domestic and international business taxation, beginning with his four years as a solicitor in the London office of a leading US law firm advising on the tax aspects of cross-border M&A, debt and equity financing, and restructuring transactions.
Since joining Chambers, he has built upon this expertise with a focus on matters with both business and private client tax dimensions. He is also developing a growing practice in environmental taxation, including landfill tax and a keen interest in the Carbon Border Adjustment Mechanism.
Recent instructions include:
- advising estates on a number of complex inheritance tax and trust issues
- assisting the counsel team successfully representing HMRC before the Supreme Court in a landmark capital allowances case (Orsted v HMRC, led by Elizabeth Wilson KC and Angharad Parry KC)
- advising taxpayers (led) in a number of significant judicial review claims brought against HMRC decisions
- participating (led) in ongoing landfill tax appeals
- advising business owners on the tax aspects of the negotiations to sell their companies
- successfully representing a haulage business in its appeal against HMRC’s refusal to allow input tax recovery (D Nuttall UK Ltd v HMRC, led by Richard Vallat KC)
- acting as sole counsel for businesses in ongoing VAT disputes with HMRC
- representing multiple companies in winding-up petitions brought by HMRC
- advising HMRC (led) on substantial transfer pricing and unallowable purpose litigation
- advising on R&D relief, including in the context of a professional negligence claim where the advice contributed to a favourable settlement
He is happy to accept instructions under the Public Access scheme.
A copy of Josh’s privacy notice can be found here.
Corporate tax
Josh has extensive experience of all aspects of corporate taxation, both from working as a solicitor at a leading US law firm and now as a barrister.
Recent work includes:
- high-profile capital allowances litigation, including assisting the counsel team successfully representing HMRC before the Supreme Court in a landmark capital allowances case (Orsted v HMRC, led by Elizabeth Wilson KC and Angharad Parry KC)
- advising business owners on the tax aspects of the negotiations to sell their companies
- assisting companies to challenge disputed penalties imposed by HMRC
- advising HMRC (led) on substantial ongoing transfer pricing and unallowable purpose litigation
- representing multiple companies in resisting winding-up petitions brought by HMRC
- advising companies on R&D relief, including in the context of a professional negligence claim where the advice contributed to a favourable settlement
- assisting (led) with litigation relating to corporate residence and double tax treaties
- advising HMRC (led) on issues relating to cross-border group relief
Personal tax
Josh has a growing personal tax practice, with a particular focus on the intersection between private client and business tax issues. Recent work includes:
- advising on how Business Property Relief applies to business interests in a member of Lloyd’s
- advising on the interpretation of will trusts and the tax implications of subsequent actions of the trustees and beneficiaries
- representing a high-net worth individual (led by James Rivett KC) in a significant judicial review claim brought against HMRC decision-making concerning the conduct of HMRC’s role under a double tax treaty
- advising (led) in respect of complex tax issues concerning domicile, offshore structures, and public law challenges to HMRC decision-making
VAT / IPT & other indirect taxes
Josh has a broad range of experience across indirect tax, customs and duties.
Recent work includes:
- representing a small business in an ongoing customs dispute with HMRC
- representing a business in ongoing fuel duty litigation
- participating (led) in ongoing landfill tax appeals
- representing the taxpayer (led by James Rivett KC) in the Upper Tribunal in Healthspan Ltd v HMRC, which concerned procedural questions of expert evidence in the context of the meaning of ‘food’ for VAT purposes
- acting as sole counsel for businesses in substantial ongoing VAT disputes with HMRC
- successfully representing a haulage business in its appeal against HMRC’s refusal to allow input tax recovery (D Nuttall UK Ltd v HMRC, led by Richard Vallat KC)
- successfully representing HMRC regarding the interpretation of VAT legislation passed during the COVID-19 pandemic (JD Wetherspoon plc v HMRC, led by Ben Elliott)
Josh has also written on the Cross Border Adjustment Mechanism.
International & offshore
Josh has extensive familiarity with the fast-moving world of cross-border tax issues from his time as a solicitor at an international law firm, which he continues to develop in his current practice.
Recent work has required consideration of the interpretation and application of double tax treaties, analysis of complex international group and trust structures, and the Pillar Two rules.
Public Law
Josh has considerable experience in bringing judicial review on behalf taxpayers, including:
- advising individuals on the merits of a claim for judicial review
- representing a high-net worth individual (led by James Rivett KC) in a significant judicial review claim brought against HMRC decision-making concerning the conduct of HMRC’s role under a double tax treaty
- bringing judicial review (led) and making disclosure applications in respect of HMRC decision-making regarding domicile
- bringing claims for judicial review (led) in respect of companies in financial distress that are unable to file audited accounts
Career
- 2022 – 2023 – Pupillage, Pump Court Tax Chambers
- 2018 – 2022 – Associate Solicitor, Sullivan & Cromwell LLP
- 2016 – 2018 – Trainee Solicitor, Sullivan & Cromwell LLP
Education
- 2015 – 2016 – Kaplan Law School – LPC (Distinction)
- 2014 – 2015 – Trinity College, Oxford – BCL (Distinction)
- 2011 – 2014 – Downing College, Cambridge – BA (Law) (Double First)
Scholarship and Prizes
- Clarendon-Beloff Scholarship (Trinity College, Oxford)
- Foundation Scholar and Senior Harris Scholar (Downing College, Cambridge)
- Graeme Hill Prize for Especial Distinction in Law Part II (Cambridge)
- Platt Prize for Especial Distinction in Law Part IB (Cambridge)
- Sweet and Maxwell Prize for highest overall 1st in Law Part IA (Cambridge)
Memberships
- Revenue Bar Association (RBA)
- VAT Practitioner’s Group (VPG)
Books
Tax Litigation Handbook 2024
