18 St John Street’s Tax Litigation Group is the largest group of specialist tax litigation barristers outside London. Members act for individual and corporate taxpayers, in disputes of all levels of complexity and value.
The tax litigation group advises and represents taxpayers in disputes with HMRC and UKBF concerning all taxes and duties. Members of the group have expertise in litigating disputes about income and corporation tax, VAT (including VAT fraud), Inheritance Tax, Stamp Duty Land Tax, Gaming Duties, customs and excise duties, condemnation and restoration proceedings.
In order to enhance the quality of the services that the Tax group is able to offer, it also includes a number of criminal practitioners with expertise in fraud.
Members are able to advise and represent either in person or remotely at the First-tier Tribunal and the Upper Tribunal and facilities are in place to host legal teams and clients in chambers should it be required adhering to our strict Covid – 19 Protocol.
Many appeals are brought, and lost, by the taxpayer because the wrong approach was taken with HMRC before legal advice was obtained. The right approach, setting out the facts and law in a way which appeals to HMRC, can often help narrow or even completely resolve a dispute without the need for an appeal. Our members can provide early advice to progress a case quickly.
Many taxpayers do not know that HMRC has an Alternative Dispute Resolution procedure, which aims –with the assistance of a mediator – to resolve tax disputes without the need for a formal appeal to the Tribunal. We can advise and represent taxpayers at such meetings.
We aim to advise promptly, in writing or in person. If an appeal enjoys no chance of success, we will tell you as early as possible, to save you the time and expense of a hopeless appeal. If an appeal is brought, we can advise and assist in the drafting of all necessary documents, and in representing clients before the Tribunal. Only 20% of taxpayers’ appeals before the Tribunal are successful. We can help you improve your chance of being in that 20%.
Recent cases in which members have been involved include:
Wilhunter (UK) Ltd v HMRC [2021] UKFTT 265 (£6.7m corporation tax; First-tier Tribunal)
E Rider Ltd v HMRC [2021] UKFTT 209 (TC) (Excise seizure of e-bikes)
Candy v HMRC [2021] UKUT 170 (TCC) (£1.8m SDLT; Upper Tribunal)
Scoggins v HMRC [2021] UKFTT 159 (TC) (Discovery assessments; First-tier Tribunal)
Roger Preston Group Ltd v HMRC [2021] UKFTT 38 (TC) (Corporation Tax; Amortisation of goodwill)
Rarter Ltd v HMRC [2021] UKFTT 464 (TC) (Excise duty; First-tier Tribunal)
G B Fleet Hire Ltd [2020] UKFTT 365 (TC) (£1.3m VAT; First-tier Tribunal)
Mainpay Ltd v HMRC [2020] UKFTT 204 (TC) (£165,000 VAT; First-tier Tribunal)
Pyramid Distribution Ltd v HMRC [2020] UKFTT 27 (TC) (£216,000, VAT MTIC; First-tier Tribunal)
Charnley v HMRC [2019] UKFTT 650 (TC) (£1m IHT; First-tier Tribunal)
Management and clerking team
James Parks – Chambers Director jparks@18sjs.com 0161 278 8261 – 07968 289 252
Katie Brown – Senior Clerk kbrown@18sjs.com 0161 278 8261
Ryan Pugh – Deputy Senior Clerk rpugh@18sjs.com 0161 278 8261
Seminars
We offer in-house seminars, typically on a weekday at 5pm. All our speakers are accredited by the Bar Council and The Law Society.