Stephen Brandon QC


  • “Absolutely superb in court” and “strong analytical ability and profound knowledge”: 2011 Chambers & Partners Tax (Private Client).

  • “Huge depth of knowledge and fantastic performance in court” and “multi-talented, considerate and approachable”: Chambers & Partners 2011: Tax, London (Corporate).

Practice

Appointed Queen's Counsel in 1996.

Became head of chambers in 2007.

Fellow of the Chartered Institute of Taxation.

Advises on all aspects of tax law.

Particularly experienced in business taxation including international transactions, international tax disputes,Treaty Relief,advising foreign domiciled individuals and entrepreneurs.

Welcomes litigation and has conducted appeals before Commissioners and the Transactions in Securities Tribunal (more recently in the First Tier and Upper Tribunals) to the House of Lords and before foreign tax tribunals.

Experienced at in-depth analysis of complex provisions in disputes with HMRC.

Author of Taxation of Non-Resident Companies and their Shareholders and numerous articles.

Articles

Numerous articles including the following:

Transaction in Securities 2010.

TCGA 1992, SECTION 13 (5A): DOUBLE TAXATION,CREDITS AND RECOVERY;

Was the decision in Strand Options correct?

Transfer-Pricing and Rental Income: "Thin-Cap" Corpse revived.

Taxable Remittances (1): A Plain Person's Guide to Law, Fact & Myth.

Taxable Remittances (2)

ICTA 1988 s.146 & R v Allen: Must the Client Throw in the Towel?

Unwinding Offshore Structures.

The Taxpayer's Privilege, Taxation.

Offshore Schemes: Foreign Companies & Criminal Liability.

ICTA 1988 s.739: Isolating the Causal Relationships.

Compensation: The Conceptual Basis of VAT.

ICTA 1988 s.739 & Double Taxation Relief: An Offshoot from CIR v. Willoughby.

CGTA 1979 s.15: Slaying the Dragon.

Publications

Publications include:

Taxation of Non-Resident and Migrant Companies
Key Haven Publications 1989).

Foreign Companies and the Danger of UK Residence
(Key Haven Publications, 1991).

The Taxation of Non-UK Resident Companies and their Shareholders
(Key Haven Publications, 2005).