Tax

Members of Fountain Court Chambers combine specialist tax expertise with broader practices across corporate, insolvency, employment and restructuring offerings, and also leveraging the set’s top-tier banking and finance experience. 

Drawing on its strength as a leading commercial litigation set, together with deep Chancery, offshore and corporate litigation expertise, Fountain Court is well placed to advise and act in major tax avoidance and transfer pricing disputes. Members have longstanding experience representing HM Revenue & Customs at both junior and senior levels, including in government panel litigation, and have acted for HMRC in substantial cases such as Re AstraZeneca plc v HMRC and Reed Employment v HMRC. This experience reflects the set’s ability to manage large‑scale, legally and factually complex tax litigation involving lengthy time estimates and extensive case management. 

Recent tax avoidance matters include ‘gold bullion’ schemes and umbrella employment. Members are also used to dealing with the overlap between tax and employment litigation, illustrated by their work in IR35 cases involving TV presenters such as Adrian Chiles, and Eamonn Holmes, as well as employment status cases involving high-profile individuals such as Sir Bradley Wiggins. 

Our work includes cases relating to: 

  • Corporate tax 
  • Fraud 
  • Negligence claims relating to tax advice 
  • Personal tax
  • Tax avoidance schemes – including film finance arrangements
  • Transfer pricing
  • VAT / indirect tax 

              • DSG Retail v HMRC : Fountain Court members acted in one of the first transfer pricing case to be litigated before the (then) Special Commissioners.
              • Re Paycheck Services Ltd; HMRC v Holland: Leading authority on the question of de facto directors and the use of corporate directors in tax avoidance schemes.
              • Investors in the Scotts Atlantic Film Finance Scheme v Andrew Thornhill QC: Acting for over 100 investors who allege they were negligently advised by a barrister that investing into a film scheme would successfully allow them to mitigate tax liabilities.
              • Rowe & Ors v Ingenious Media Holdings plc & Ors: Acting for various parties in relation to claims concerning advice given regarding investments in the Ingenious film partnerships.
              • Red White & Green v HMRC: Acting in this IR35 dispute involving Eamonn Holmes and ITV.
              • Wired Orthodontics v HMRC: Acting in this dispute regarding tax avoidance, relating to a gold bullion scheme and an employee benefit trust. The matter involved issues of without prejudice privilege and legal professional privilege.
              • Christa Ackroyd Media v HMRC: Acting in this IR35 dispute in the Upper Tribunal decision in the context of TV broadcasting.
              • Reed Employment v HMRC: Acting in this dispute regarding tax avoidance, relating to a home-to-work travel expenses scheme for temporary employees.
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              Tax Barristers

              Richard Coleman QC

              Richard Coleman KC

              Call 1994 | Silk 2012

              Stuart Ritchie QC

              Stuart Ritchie KC

              Call 1995 | Silk 2012

              Adam Tolley QC

              Adam Tolley KC

              Call 1994 | Silk 2014

              Clare Sibson KC

              Call 1997 | Silk 2016

              John Mehrzad KC

              Call 2005 | Silk 2020

              Ian Simester

              Call 2022

              Andrew Currie

              Call 2024

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              Contact our clerks

              For more information on our experience or to discuss a particular case, please contact us.

              Call:    +44 (0)207 583 3335
              Email: clerks@fountaincourt.co.uk

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