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:
MATEUSZ ZIOMEK v Revenue & Customs (EXCISE DUTY-Restoration-Seizure of vehicle on entry to UK-Appeal against decision to restore vehicle for a fee-Whether decision reasonable and proportionate on the facts-Yes- Appeal dismissed) [2022] UKFTT 444 (TC) (30 November 2022) (View without highlighting) [4%]
([2022] UKFTT 444 (TC); From First-tier Tribunal (Tax); 66 KB)
Revenue and Customs v Dolphin Drilling Limited [2022] UKUT 212 (TCC) (4 August 2022) (View without highlighting) [8%]
([2022] UKUT 212 (TCC); From United Kingdom Upper Tribunal (Tax and Chancery Chamber); 93 KB)
WILLIAM RAYMOND RUSKE v Revenue & Customs (CUSTOMS DUTIES – EXCISE DUTIES – civil evasion penalties) [2022] UKFTT 310 (TC) (27 July 2022) (View without highlighting) [6%]
([2022] UKFTT 310 (TC); From First-tier Tribunal (Tax); 33 KB)
ULSTER METALS v Revenue & Customs (PROCEDURE : Other) [2022] UKFTT 125 (TC) (07 April 2022) (View without highlighting) [7%]
([2022] UKFTT 125 (TC); From First-tier Tribunal (Tax); 1 KB)
FIRTH AND MRS RITA FIRTHAS THE TRUSTEES OF THE L BATLEY1984 SETTLEMENT v Revenue & Customs (INHERITANCE TAX – business property relief – apart-hotel – whether business mainly holding investments) [2022] UKFTT 219 (TC) (14 July 2022) (View without highlighting) [6%]
([2022] UKFTT 219 (TC); From First-tier Tribunal (Tax); 117 KB)
COYLES MILLAR v Revenue & Customs (PROCEDURE : Other) [2021] UKFTT 481 (TC) (29 December 2021) (View without highlighting) [6%]
([2021] UKFTT 481 (TC); From First-tier Tribunal (Tax); 1 KB)
MR TIBOR JANOS MOZER v Revenue & Customs (PROCEDURE : Other) [2021] UKFTT 475 (TC) (13 December 2021) (View without highlighting) [4%]
([2021] UKFTT 475 (TC); From First-tier Tribunal (Tax); 2 KB)
BROOKS v Revenue & Customs (CUSTOMS DUTY and VAT – Transfer of Residency Relief – Brexit – Covid 19) [2021] UKFTT 449 (TC) (03 December 2021) (View without highlighting) [5%]
([2021] UKFTT 449 (TC); From First-tier Tribunal (Tax); 39 KB)
GARY TURTONMATTHEW ADAMS v Revenue & Customs (EXCISE DUTY – Appeal against assessment) [2021] UKFTT 441 (TC) (26 November 2021) (View without highlighting) [4%]
([2021] UKFTT 441 (TC); From First-tier Tribunal (Tax); 89 KB)
SWIECKI v Revenue & Customs (PROCEDURE : Other) [2021] UKFTT 407 (TC) (09 November 2021) (View without highlighting) [5%]
([2021] UKFTT 407 (TC); From First-tier Tribunal (Tax); 58 KB)
Zobortrans EU S.R.O. v Revenue & Customs (application for appeal out of time) [2021] UKFTT 402 (TC) (05 November 2021) (View without highlighting) [6%]
([2021] UKFTT 402 (TC); From First-tier Tribunal (Tax); 1 KB)
Mr Karl French v Revenue & Customs (CUSTOMS AND EXCISE CIVIL EVASION PENALTY) [2021] UKFTT 401 (TC) (01 November 2021) (View without highlighting) [1%]
([2021] UKFTT 401 (TC); From First-tier Tribunal (Tax); 1 KB)
Mainpay Ltd v Revenue and Customs [2021] UKUT 270 (TCC) (1 November 2021) (bailii.org)
Mlekanov v Revenue And Customs (Customs & Excise Duty: strike out of appeal against assessment as no claim had been made) [2022] UKFTT 357 (TC) (30 September 2022) (View without highlighting) [5%]
([2022] UKFTT 357 (TC); From First-tier Tribunal (Tax); 40 KB)
G B Fleet Hire Limited v Revenue and Customs [2021] UKUT 225 (TCC) (14 September 2021) (View without highlighting) [4%]
([2021] BVC 514, [2021] UKUT 225 (TCC); From United Kingdom Upper Tribunal (Tax and Chancery Chamber); 0 KB)
SC Duvenbeck Logistik SRL The Director of Border Revenue (EXCISE DUTIES – refusal to restore vehicle) [2021] UKFTT 319 (TC) (06 September 2021) (View without highlighting) [4%]
([2021] UKFTT 319 (TC); From First-tier Tribunal (Tax); 1 KB)
Matthew & Ors v Sedman & Ors [2021] UKSC 19 (21 May 2021) (View without highlighting) [3%]
([2021] 2 P & CR DG18, [2021] 2 WLR 1232, [2021] 4 All ER 477, [2021] UKSC 19, [2022] AC 299; From United Kingdom Supreme Court; 71 KB)
Wilhunter (UK) Ltd v Revenue & Customs (Corporation Tax – oil contractor activities) [2021] UKFTT 265 (TC) (14 July 2021) (View without highlighting) [8%]
([2021] UKFTT 265 (TC); From First-tier Tribunal (Tax); 62 KB)
E Rider Ltd v Revenue & Customs (Excise – seizure of electric bicycles and window tint film) [2021] UKFTT 209 (TC) (9 June 2021) (View without highlighting) [139%]
([2021] UKFTT 209 (TC); From First-tier Tribunal (Tax); 73 KB)
Revenue and Customs v Christian Peter Candy [2021] UKUT 170 (TCC) (12 July 2021) (View without highlighting) [3%]
([2021] 4 WLR 130, [2021] BTC 535, [2021] STC 1500, [2021] STI 1888, [2021] UKUT 170 (TCC), [2021] WLR(D) 532; From United Kingdom Upper Tribunal (Tax and Chancery Chamber); 0 KB)
Mr N Scoggins v Revenue & Customs (Income Tax – Discovery Assessments) [2021] UKFTT 315 (TC) (15 May 2021) (View without highlighting) [283%]
([2021] UKFTT 315 (TC); From First-tier Tribunal (Tax); 1 KB)
Lorraine McLaren v Revenue & Customs (PROCEDURE : Other) [2021] UKFTT 130 (TC) (30 April 2021) (View without highlighting) [2%]
([2021] UKFTT 130 (TC); From First-tier Tribunal (Tax); 1 KB)
Rajeswary v Revenue & Customs (Appeal – refusing to restore vehicle seized) [2021] UKFTT 206 (TC) (2 March 2021) (View without highlighting) [2%]
([2021] UKFTT 206 (TC); From First-tier Tribunal (Tax); 196 KB)
Roger Preston Group Ltd v Revenue and Customs (CORPORATION TAX – Accountancy treatment and amortisation of assets sold) [2021] UKFTT 38 (TC) (9 February 2021) (bailii.org) (Corporation Tax; Amortisation of goodwill)
Rarter Ltd v Revenue & Customs (Excise Duty – Whether Valid Movement Guarantee In Place) [2020] UKFTT 464 (Tc) (12 November 2020) (View without highlighting) [292%]
([2020] UKFTT 464 (Tc); From First-tier Tribunal (Tax); 83 KB) (Excise duty; First-tier Tribunal)
Pyramid Distribution Ltd v Revenue & Customs (VAT- MTIC- denial of input VAT) [2020] UKFTT 27 (TC) (15 January 2020) (View without highlighting) [259%]
([2020] UKFTT 27 (TC); From First-tier Tribunal (Tax); 175 KB)
Charnley & Ors v Revenue & Customs (INHERITANCE TAX : Business : agricultural reliefs) [2019] UKFTT 650 (TC) (28 October 2019) (View without highlighting) [268%]
([2019] UKFTT 650 (TC), [2020] WTLR 93; From First-tier Tribunal (Tax); 152 KB)
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.