Sadiya Choudhury KC

  • Call: 2002
  • Silk: 2024


Sadiya was called to the Bar in 2002 and became a member of Chambers following completion of her second six pupillage in 2003. She has a broad advisory and litigation practice across all areas of direct and indirect tax law. She has appeared by herself, as a junior and as a leader in several cases in the specialist tax tribunals as well as courts at all levels.

Before taking silk in 2024, Sadiya was a member of the Attorney General’s A Panel and regularly appeared on behalf of HMRC, the National Crime Agency and other government departments. She is happy to accept instructions under the Public Access scheme.

She has a particular interest in excise and customs duties.  She also accepts instructions in relation to tax issues which have arisen in another area of the law, such as ancillary relief proceedings. She has considerable experience of judicial review proceedings for both taxpayers and HMRC.

A copy of Sadiya's privacy notice can be found here.

Recent cases

Examples of a few of her recent cases include:


Delinian Ltd (Formerly Euromoney Institutional Investor PLC) v HMRC [2023] EWCA Civ 1281: junior counsel for HMRC in a case concerning the scope of the provisions in sections 135 to 137 Taxation of Chargeable Gains Act 1992 and whether the share exchange at issue formed part of a scheme or arrangements which had a main purpose of tax avoidance.


Caerdav Ltd v HMRC [2023] UKUT 179 (TCC): counsel for the taxpayer in an appeal concerning the VAT and customs duty liability of the importation of an aircraft.


HMRC v Jasper Conran; JC Vision Ltd v HMRC [2023] UKUT 166 (TCC): junior counsel for HMRC in appeals involving the value of the goodwill transferred from an LLP to a company and whether the ultimate shareholder had received a distribution. The UT decided both appeals in HMRC’s favour.


Marano v HMRC [2023] UKUT 113 (TCC): counsel for HMRC in an appeal in which the UT confirmed that a HMRC notice issued by a computer was valid, as the UT had also previously decided in Allam v HMRC [2021] UKUT 291 (TCC).


Spring Capital Ltd v HMRC [2023] UKUT 91 (TCC): junior counsel for HMRC in an appeal concerning whether Scots law is foreign law in the tax tribunal. The UT confirmed that the tax tribunal has a UK-wide jurisdiction.


Norton & anor v HMRC [2023] UKUT 48 (TCC): counsel for HMRC in an appeal concerning the income tax rules governing benefits in kind arising from the use of a car.


Harrison v HMRC [2023] UKUT 38 (TCC): counsel for HMRC in an appeal in which the UT confirmed that the concept of “staleness” was no longer a valid basis for discharging a discovery assessment following the Supreme Court’s decision in HMRC v Tooth.


HMRC v BlackRock Holdco 5 LLC [2022] UKUT 205 (TCC): junior counsel for HMRC in an appeal in which the UT reversed the FTT’s decision and found that the corporation tax relief claimed by the taxpayer was not available under both the transfer pricing and loan relationships legislation.


Exchequer Solutions Ltd v HMRC [2022] UKFTT 181 (TC): junior counsel for HMRC in an appeal brought by an umbrella company on the deductibility of expenses paid to its workers.

Income Tax

Disguised remuneration

PAYE operation

Statutory residence test

Transfer of assets abroad

Payments on employment termination

Inheritance Tax

Drafting and interpreting wills, trusts and deeds of variation

Business property relief/Agricultural property relief

Gifts with reservation

Capital Gains Tax

Company re-organisations

Entrepreneurs’ relief

Transfers of property in ancillary relief proceedings

PPR relief

Benefits received from offshore trusts

Corporation Tax

Capital reduction demergers

Loan relationship provisions

Loans to participators

Transfer pricing

Transfers of goodwill


Import VAT

Option to tax

“Best judgment” assessments

Classification for zero-rating purposes


Group relief and application of clawback provisions


Partnership transfers

Linked transactions

Sub-sale relief


Excise Duty

Detention and seizure of alcohol from a warehouse

Condemnation proceedings

Assessment and penalty proceedings for non-duty paid goods

Penalty proceedings for irregularities in documentation

Seizure of goods subject to CITES

Customs Duty

Customs classification

Customs value of goods

Import quotas

Remission applications


Information notices

Discovery assessments

Late appeals

Strike-out applications



Jackson’s Matrimonial Finance (10th Edition): Author of the Taxation chapter

Sadiya also regularly lectures on a range of tax-related issues.


Revenue Bar Association

VAT Practitioners Group



Kinnaird College, Lahore, Pakistan: BSc (Pure Sciences, First)

St Edmund Hall, Oxford: M.A. (Jurisprudence, First)

Inns Court School of Law: Bar Vocational Course (Very Competent)

Denning and Sunley Scholarships, Lincoln’s Inn


Urdu (bilingual), Hindi, Punjabi

Related judgements