Members of Fountain Court Chambers maintain their tax practices alongside the set’s existing corporate, insolvency, and restructuring offerings, whilst also leveraging their top-tier banking and finance experience.
The set brings all its experience as a commercial litigation set, together with relevant Chancery, offshore, and corporate litigation expertise to bear in assisting on tax avoidance and transfer pricing cases. Our work is informed by our provenance in handling the mechanics of large-scale, factually and legally complex tax litigation.
Members have represented Her Majesty’s Revenue & Customs at junior and senior levels, including some having acted in government panel litigation for over five years or more.
Our work in large tax avoidance and transfer pricing cases on behalf of HMRC, in cases like Re AstraZeneca plc v HMRC showed our ability to manage legally and factually complex areas of tax litigation with lengthy time estimates and extensive case management.
The set has acted in one of the first transfer pricing case to be litigated before the (then) Special Commissioners in DSG Retail v HMRC (2009), as well as at all stages of the Re Paycheck Services Ltd; HMRC v Holland (2009) litigation, which is the leading authority on the question of de facto directors and the use of corporate directors in tax avoidance schemes.
It has also acted in substantial carousel VAT fraud cases and cases concerning film finance schemes.