William Massey QC

Called: 1977

QC: 1996

William Massey QC

William Massey’s practice covers all areas of personal and corporate taxation, tax appeals and other tax related litigation. He is best known for his expertise in private client tax, particularly in estate tax planning, heritage property, conditional exemption, business and agricultural property reliefs, and trust tax planning (including variations of trust under the Variation of Trusts Act).

  • Career

    Called 1977, Middle Temple, elected a Bencher (2004)

    QC 1996

    Governor, Harrow School (2000-2013) Summer Fields School (1996-2013)

    Member, Tax Committee, Historic Houses Association

  • Notable cases

    Professional Footballer’s Association (Enterprises) Ltd v C&E (House of Lords – VAT,  supply of trophy to winners at PFA awards dinner not chargeable to VAT); Caton’s Administrators v Couch (Court of Appeal – CGT, share valuation principles); Westmorland Motorway Services Ltd v C&E (Court of Appeal – VAT free meals to coach-drivers at service stations); Fallon v Fellows (High Court – CGT, ‘press release’ reconstruction not a true reconstruction so no reduction in base cost); Lloyds TSB (prs of Antrobus deceased) v IRC (Special Commissioners – IHT, Agricultural Property Relief on ‘farmhouse of a character appropriate’); Application to vary the undertaking of A and B (Special Commissioners – IHT, proposed alteration to conditional exemption undertakings ); Marquess of Hertford and others v IRC (Special Commissioners – IHT, Business Property Relief on whole value of historic house most of which was open to the public); McCall v HMRC (Northern Ireland Court of Appeal – IHT, whether Business Property Relief available on grazed farmland); Trustees of the Nelson Dance Family Settlement (High Court – IHT, Business Property Relief available on transfer of business asset); AC v DC & Ors (Financial Remedy: Effect of s. 37 Avoidance Order) (High Court – CGT, s.37 order avoids  transaction ab initio for CGT); V v T/A (High Court – variation of trust under VTA 1958 – measures appropriate to balance right to public hearing with right to privacy); Executors of Lord Howard of Henderskelfe v HMRC (Court of Appeal – CGT, sale of Reynolds ‘Portrait of Omai’ at Castle Howard eligible for CGT exemption as ‘plant’)

  • Publications

    Editorial Board – Simon’s Direct Tax Service

  • Memberships

    Revenue Bar Association

    Chancery Bar Association

    London Common Law & Commercial Bar Association

  • Education

    Harrow School

    Hertford College, Oxford (MA (Jurisprudence))

  • The Chambers Guide says...

    Tax: Private Client
    Ranking: Star Individual

    Best known for his private client work, with his expertise lying in trust and estate tax planning, business and agricultural property relief, heritage property and exemption. Massey’s work on complex trust and inheritance tax issues is especially noted.
    “He is the great star of the private client Tax Bar. He has this reputation where people think if he thinks something, then it must be right.” “He has a good reputation for landed and heritage matters. He is just brilliant at relating to families and he can get to the nub of the matter really quickly; he is excellent and has been a great resource.” “He has real gravitas, he’s very strong on Inheritance Tax, he’s very thoughtful and has a very rounded view.” (2019)

    . . . “William is definitely frontline for IHT. When I’ve got William’s advice I will always take my time to read it carefully. He’s also very flexible, I can ring him whenever I need to and he’s always got time for the job because he’s innately interested in what he’s doing, and it shows.” “I always use him for complex matters. He is extremely thorough and learned but puts things into easily understandable language.” (2018)

    A leading silk in the Private Client Tax Bar, who is extremely experienced in a variety of areas, including tax and estate planning, agricultural property, BPR and APR. He has represented clients in the High Court and Supreme Court. He continues to grow his practice in matrimonial finance-related work. “Famously ‘the best in town’ when it comes to tax and landed estates.” “He is very masterful when it comes to dealing with the taxation issues affecting landed estates. To find a QC who can steer you around the law is absolutely essential, and Massey is one of the most capable landed estate tax barristers.” (2017)

    Agriculture & Rural Affairs
    Ranking: Band 1

    Recognised as the leading expert on the tax aspects specific to landed estates and agricultural land. He is particularly well known for his work on matters concerning heritage property and the succession of farms and estates. Peers further acknowledge his in-depth knowledge of business assets requiring agricultural relief.
    “Famously ‘the best in town’ when it comes to tax and landed estates.” “If you really want a good and reliable answer, he’s just excellent. He has fantastic written work: if you say ‘I’m going to consult William Massey,’ everyone sort of goes into hushed tones. He’s the gold standard, really.” (2019)

    . . . “Incisive, thorough and a real expert, he has been the go-to person for at least ten years on all matters of agricultural relief and heritage property. He’s extremely good.” (2018)

    Widely regarded as the leading light for cases concerning tax issues relating to landed estates. Heritage property, agricultural property relief and estate tax planning are all areas of expertise for him.  “William is at the very top of his tree and is very clear with clients.” “Without doubt, the leading tax QC for heritage matters.” (2017)

  • The Legal 500 says...

    Private Client: Personal Tax
    Ranking: Leading Silk, Tier 1

    ‘Has a great ability to communicate complicated issues clearly and succinctly.’ (2018)

    ‘Thoughtful and methodical; he identifies even issues that may not fall within his expertise.’ (2017)

    ‘A quietly persuasive advocate with unmatched expertise in trusts and heritage property.’ (2016)

  • Chambers and Partners HNW says...

    Tax: Private Client

    Ranking: Leading Silks, Star Individual

    William Massey QC “is the great star of the private client Tax Bar,” says a market insider, adding: “He has this reputation where people think if he thinks something, then it must be right.” “He has a good reputation for landed and heritage matters. He is just brilliant at relating to families and he can get to the nub of the matter really quickly; he is excellent and has been a great resource,” reports one interviewee. Another comments: “He has real gravitas, he’s very strong on Inheritance Tax, he’s very thoughtful and has a very rounded view.” Massey is also praised for his “technical abilities, charming manner, and his ability to explain complex points clearly.”

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