Overview
Stacey joined Pump Court Tax Chambers as a tenant in October 2024 on completion of her pupillage. She has a varied litigation and advisory practice across all areas of chambers’ expertise including personal tax, corporate tax, and VAT and other indirect taxes. She has particular interests in offshore matters, judicial review and human rights, employment law aspects of taxation and EU law. She also has a thorough grounding in procedural and case management issues including matters relating to witnesses, documentary evidence and pleadings, as well as significant experience in respect of HMRC assessments and penalties.
Stacey’s litigation work includes cases in the First-tier Tribunal (Tax Chamber), the Upper Tribunal (Tax and Chancery Chamber) and the Court of Appeal, as well as regular unled appearances for taxpayers responding to HMRC petitions in the Insolvency and Companies Court. Please see her ‘Litigation’ tab for further details.
Stacey’s advisory work includes small- and large-scale planning on VAT and other indirect taxes, private client offshore planning and company reorganisations, as well as advice on early-stage HMRC enquiries and penalty investigations. Please see her ‘Advisory Work’ tab for further details.
Stacey enjoys giving talks at conferences and authoring articles. Recent examples include a talk on recent VAT cases at the CIOT Indirect Taxes Annual Conference and a cover article in Tax Journal on the developing case law on late appeals in the tax tribunals.
Prior to taking her law degree and BCL at the University of Oxford and then joining the Bar, Stacey was a neuroscientist and holds a BA in Natural Sciences (Neuroscience) and a PhD in Neuroscience from the University of Cambridge. Her scientific background gives her a significant advantage when dealing with matters of technical or factual complexity.
Stacey is qualified to accept instructions under the Public Access scheme.
A copy of Stacey’s privacy notice can be found here.
Litigation
Stacey’s recent unled litigation work includes representing a taxpayer in their late appeal against a VAT assessment and led work has included:
- Odfjell Technology (UK) Ltd v HMRC [2025] UKFTT 28 (TC): a case at the nexus of tax and employment law concerning the liability of the UK branch of a multinational oil company to secondary class I National Insurance contributions in respect of offshore employees
- Investment and Securities Trust Ltd v HMRC [2025] UKUT 331 (TCC), [2025] STC 1694: a case concerning exemption/relief from the higher-rate of SDLT and ATED in the property development trade
- BTR Core Fund JPUT v HMRC [2026] UKUT 27 (TCC), [2026] STC 84: a case concerning the conditions for the claim of SDLT overpayment relief
She also regularly provides unled representation to corporate and individual taxpayers responding to HMRC petitions in the Insolvency and Companies Court.
Upcoming cases on which Stacey is instructed include several cases in the Court of Appeal and cases involving complex issues of EU law.
She is currently instructed by HMRC as part of a team of counsel dealing with all the penalties flowing from a failed mass-market avoidance scheme, in relation to which issues of discovery assessment validity and time limits, ADR (in particular the effect of without prejudice privilege), penalty mitigation and agency-based appeals have arisen.
Advisory work
Stacey has a diverse and mostly unled advisory practice which includes advice and planning in the private client and corporate fields. A selection of her recent work includes:
Indirect taxes including VAT, SDLT, stamp duty/SDRT and landfill tax
- VAT planning involving principles of employment law applicable to a complex reorganisation of a group of companies
- VAT opinions on the purchase of leasehold property and for the operation of a right-to-manage company
- The stamp duty/SDRT implications of a £50m transfer of shares between multinationals as part of an arbitration settlement
- The human rights arguments against a series of landfill tax penalties
Private client offshore planning
Planning advice for high-net worth individuals, both UK resident and non-UK resident, on navigating the UK inheritance tax net and anti-avoidance regimes including the Transfer of Assets Abroad regime, the trust gains matching regime and the onward gifting rules.
Company reorganisations
Tailored advice on corporate reorganisations including the interaction of company and tax law concepts and the optimisation of the use of CGT, VAT and SDLT reliefs.
Domestic wills, estates and IHT
- Drafting of trust instruments and deeds of variation
- Advice on various aspects of inheritance tax including dispositions that are not transfers of value, exempt transfers and the allocation of exemptions, and the relevant property regime.
- Advice on the construction of an ambiguous residuary gift under a will, including the use of the cy-près doctrine
Income tax and pensions
- Advice on the effect of the disguised remuneration provisions and the characterisation for tax purposes of sums under settlements with former workers.
- Advice on the deduction of expenses for sole traders.
- Pension succession planning in respect of the tax efficient transfer of a pension between schemes.
