Overview
Quinlan acts and advises on all areas of revenue law and on tax-related disputes. He is ranked as a leading tax junior in corporate tax and VAT and excise by Legal 500, which notes his “fierce intellect” and “very approachable” manner.
Quinlan’s recent litigation experience includes succeeding in what the Upper Tribunal described as a “bold attack” that overturned at least four previous Upper Tribunal decisions from the past seven years as “clearly wrong”, and a six-day First-tier Tribunal hearing acting unled for five taxpayers appealing against discovery assessments issued following round-the-world CGT planning (he is acting unled for a total of 16 taxpayers who used similar planning with more than £17m of tax at stake). He also has extensive experience advising across all areas of revenue law including corporate and employment taxes, private client taxation and VAT and other indirect taxes.
Quinlan has experience acting and advising on tax-related professional negligence, commercial and insolvency disputes, including settling disputes at mediation.
He was appointed to the Attorney-General’s ‘B’ panel in 2025 and is qualified to accept Public Access instructions.
A copy of Quinlan's privacy notice can be found here.
Corporate and employment taxes
Quinlan has experience advising and litigating on corporate and employment taxes including R&D relief, unallowable purpose, mixed member partnerships, disguised remuneration (Part 7A), pensions (including liberation schemes and the treatment of historic EFRBS), the activities of public bodies, the bank levy, the oil contractors regime, intermediaries legislation, image rights and the taxation of employment payments made by unincorporated associations.
Recent decisions include:
- Dolphin Drilling Ltd v HMRC [2025] UKSC 24 (also [2024] EWCA Civ 1) – acted for HMRC (led by David Ewart KC) in the Court of Appeal and Supreme Court in a case concerning the construction of “incidental” in the oil contractors regime. Made oral submissions in the Supreme Court.
- Bryan Robson v HMRC [2025] UKFTT 56 (TC) (hearing in the UT forthcoming) – acting (led by James Rivett KC) for the personal services company of former England and Manchester United captain Bryan Robson on an appeal concerning IR35 and payments for image rights.
- Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC) (permission to appeal to the UT granted following oral hearing: [2025] UKUT 338 (TCC)) – acting for the taxpayer (led by Julian Ghosh KC, with Charles Bradley and Laura Ruxandu) in an appeal concerning the application of the unallowable purpose provisions in ss. 441 and 442 CTA 2009.
- Kwik-Fit Group Ltd & Ors v HMRC [2024] EWCA Civ 434 (CoA) – acted for the taxpayer (led by Julian Ghosh KC, with Laura Ruxandu) in an appeal concerning the application of the unallowable purpose provisions in ss. 441 and 442 CTA 2009.
- Basic Broadcasting Ltd v HMRC [2022] UKFTT 48 (TC) and [2024] UKUT 165 (TCC) – acted (led by James Rivett KC) for the personal services company of television and radio presenter Adrian Chiles in a seven-day FTT hearing and two-day UT hearing on the application of IR35.
- Strategic Branding Ltd v HMRC [2021] UKFTT 474 (TC) – acted for HMRC (led by Julian Ghosh KC, with Barbara Belgrano and Laura Ruxandu) successfully responding to an appeal against PAYE determinations and NICs decisions relating to a remuneration trust avoidance scheme.
VAT and other indirect taxes
Quinlan has an extensive VAT and indirect taxes practice in which he advises on and litigates the range of indirect taxes including VAT, SDLT, Land Transaction Tax, ATED, Customs and Excise Duties, Aggregates Levy and General Betting Duty.
Recent decisions include:
- Medpro Healthcare Ltd v HMRC [2025] UKUT 255 (TCC) – acting for the taxpayers (leading Sam Glover) in a successful appeal against the FTT’s refusal to give permission to bring late appeals against penalties on four grounds including inadequacy of reasons. In a split decision, the UT accepted Quinlan’s “bold attack” on part of the decision in Martland v HMRC [2018] UKUT 178 (TCC), which laid down widely applied principles on when a taxpayer may bring a late appeal. HMRC have been granted permission to appeal to the Court of Appeal.
- Performance Leads Ltd v HMRC [2025] UKFTT 660 (TC) – acting for the taxpayer (leading Arthur Wong) in a successful appeal against HMRC’s decision that the company was not supplying exempt financial intermediary services.
- TalkTalk Telecom Ltd v HMRC [2024] UKUT 284 (TCC) and [2023] UKFTT 12 (TC) – acted for the taxpayer (led by Andrew Hitchmough KC) in FTT and UT hearings considering whether TalkTalk was only required to account for VAT on a discounted sum irrespective of whether a customer took advantage of the offer. Also issues of compatibility with the EU VAT directive.
- Medpro Healthcare Ltd v HMRC (FTT, unreported) – acting for the taxpayers (leading Sam Glover) in a two-day hearing considering the taxpayers’ three applications for permission to bring late appeals and successfully resisting two applications by HMRC to strike out parts of the taxpayers’ appeals.
- HMRC v LG Park HT1 Ltd v ors [2023] EWCA Civ 1193 (also [2022] UKUT 178 (TCC), and [2020] UKFTT 242 (TC)) – acted for the taxpayers (led by Rupert Baldry KC) in an application for the FTT to refer the question of the market value of the leases to the Upper Tribunal (Lands Chamber). Also considered the scope of closure notices.
- Mercy Global Consult Ltd v Adegbuyi-Jackson & Ors [2023] EWCA Civ 1073 – acted for Mercy (led by Rupert Baldry KC) in an appeal concerning whether an ‘umbrella’ company providing healthcare professionals who ultimately work for NHS Trusts itself made exempt supplies of “medical care”.
- Candy v HMRC [2022] EWCA Civ 1447 – acted for Mr Candy (led by Michael Thomas KC) in respect of his claim to recover overpaid SDLT.
Private client
Quinlan has a varied private client practice covering advisory work, correspondence with HMRC and litigation. Recent work for estates, individuals and family trusts has included the settlements code and the transfer of assets abroad regime (including motive defences), APR and BPR, issues relating to residence, domicile and remittances, recission and rectification, the taxation of historic EFRBS and EBTs and the taxation of litigation settlement payments.
Recent decisions include:
- Evans & ors v HMRC [2025] UKFTT 1112 (TC) – acting for the taxpayers (leading Laura Ruxandu) in a successful application for additional disclosure from HMRC. Part of appeals by 11 taxpayers appealing against closure notices issued following round-the-world CGT planning with a total value of more than £15m of tax.
- HMRC v Bunting [2025] UKUT 96 (TCC) – acting for HMRC in a successful appeal concerning the CGT provisions that allow a taxpayer who has made a loan to a trader to claim an allowable loss.
- Danapal v HMRC [2023] UKUT 86 (TCC) – acted for the taxpayer in an appeal from the FTT against discovery assessments made on the basis of deliberate behaviour. The FTT’s decision was set aside and remade to allow the taxpayer’s appeal.
- Lingajothy (t/a Flying Dragon) v HMRC [2023] UKUT 63 (TCC) – acted for the taxpayer in an appeal against the FTT having automatically struck out her appeal.
- Altan Goksu v HMRC [2022] UKFTT 213 (TC) – acted for the successful taxpayer in an appeal against a closure notice. Successfully established that the taxpayer had notified to HMRC a loss he had made in August 1998.
- Hoyle & ors v HMRC [2021] UKUT 104 (TCC) – acted for HMRC (led by Elizabeth Wilson KC) in the UT successfully defending the FTT’s case management decision not to direct the hearing of a preliminary issue.
- Warshaw v HMRC [2020] UKUT 366 (TCC) – acted for the taxpayer (led by David Ewart KC) in the FTT and UT in an appeal concerning whether shares had a right to a dividend at a fixed rate, which would have deprived the taxpayer of entrepreneur’s relief.
- Sherrington & ors v HMRC [2020] UKFTT 128 (TC) – acted for HMRC (led by Sadiya Choudhury KC) in a four-week hearing concerning the taxpayers’ use of an avoidance scheme involving losses that were said to have arisen in the course of their purported self-employment as a derivative trader.
Directory Recommendations
Legal 500 UK Bar
Tax
Ranking: Tier 3
- “Quinlan has a fierce intellect and is able quickly to cut through the detail and land on the essential points in optimising case strategy.“
Tax: VAT & Excise
Ranking: Tier 3
- “Thorough, extremely well-prepared, persuasive and very approachable.“
Education and Scholarships
Scholarships & Prizes
- Lord Denning Scholarship (Lincoln’s Inn)
- Hardwicke Entrance Award (Lincoln’s Inn)
- Sweet and Maxwell Prize for best penultimate year law exam results (QMUL)
- Dechert Prize for best contract law exam result (QMUL)
Education
- 2013-2014 – BPTC, Kaplan Law School [Very Competent]
- 2012-2013 – BCL, Lincoln College, Oxford
- 2010-2012 – LLB (Senior Status), Queen Mary, University of London [First Class]
- 2006-2009 – BA Mathematics, Churchill College, Cambridge
Career
- 2016-2017 – Pupillage, Pump Court Tax Chambers
- 2016 – Called to the Bar (Lincoln’s Inn)
- 2015-2016 – Judicial Assistant to Lord Justice Patten
- 2013-2015 – Teaching Fellow in Contract, UCL