One Motion Logistics Ltd v HMRC (in progress) 

Acting for the taxpayer in an appeal against two VAT surcharge penalty notices. Seeking to have the penalties reduced or eliminated on the basis that the penalty was disproportionate for a taxpayer with thin margins.

Taxpayer (anonymous) v HMRC (in progress)

Extensive research and drafting of a skeleton argument to argue that a VAT claim of a taxpayer dating back to 2007 was still open and that the taxpayer was entitled to amend that original claim in 2017.

Taxpayer (anonymous) v HMRC

Preparation of a technical note to the client and a statement of case for a mediation concerning a VAT dispute and whether the taxpayer was entitled to claim the margin scheme for the sale of second-hand jewellery that it was making.

Taxpayer (anonymous) v HMRC

Preparation of an agreed statement of facts related to a complicated VAT dispute and whether; Certain companies of a construction group were entitled to claim bad debt relief immediately for credit sales they had made where they had not retained title to the goods; What the entitlement of companies that had joined the VAT group later (through acquisition) was to claim bad debt relief.

Advice Anonymous client 

Employee Share Scheme: extensive research and preparation of a complex advice to a client on whether they could appeal a decision of HMRC that they did not have “reasonable excuse” under paragraph 52 of Schedule 5 of Income Tax (Earnings and Pensions) Act 2003 (“ITEPA 2003”) for failing to notify HMRC of a grant of employee stock options within 92 days of their grant under paragraph 44 of Schedule 5 of ITEPA 2003. Included considering whether the solicitors advising the client could be sued for professional negligence.

Anonymous client – Inheritance Tax

Advice and tax planning concerning an estate worth £3 million to minimise inheritance tax. Extensive research and written advice to confirm that the deceased was not domiciled or deemed domiciled in England, and therefore only her UK assets would be subject to inheritance tax. Tax saving of over £800,000 achieved.