Recent News & Events

Free Seminar on International Tax Issues – Bristol – 26 June 2018

Old Square Tax Chambers is hosting an afternoon seminar on 26 June 2018 where Philip Simpson QC, Etienne Wong and Harriet Brown will be speaking on International Tax Issues.

The seminar is to be held from 4.00 pm to 6.15 pm in the Jupiter Suite, Radisson Blu Hotel Bristol, Broad Quay, Bristol, BS1 4BY and the timetable will be as follows:

4.00 – 4.15        Tea & Coffee

4.15 – 4.50       Etienne Wong will speak on VAT & Brexit: What we know and what we could still change

4.50 – 5.25       Harriet Brown will speak on The New Deemed Domicile Rules: the new charges, limitations and reliefs

5.25 – 6.00       Philip Simpson QC will speak on Inheritance Tax and UK property: the scope and effect of the corporate look through in new Schedule A1 IHTA 1984  

6.00 – 6.15       Question to the speakers followed by drinks

Drinks will be hosted immediately after the seminar at which you will have an opportunity to meet some of the members of Old Square Tax Chambers.

The seminar is free of charge.

Please let us know if you wish to attend by emailing and do feel free to inform any colleagues who might be interested in joining us.

Corporate Tax – MBL’s 2018 Annual Conference: Sarah Squires

Sarah Squires will be speaking at MBL’s all-day annual corporate tax conference on 20 June 2018 in London.

For more information, including how to register for the conference , please click here.

Dundas Heritable Limited v. HMRC ~ Philip Simpson QC

Philip Simpson Q.C. successfully represented the taxpayer in Dundas Heritable Limited v. HMRC [2018] UKFTT 244 (TC).

The taxpayer company had filed tax returns for two years late, more than two years after the end of the accounting periods in question. The returns included claims for capital allowances. At the time the returns were lodged, the capital allowance claims were out of time. But HMRC opened enquiries into the returns. Where an enquiry has been opened into a corporation tax return, the time limit for making capital allowances claims is one month after the end of the enquiry. The question for the FTT was whether the enquiry meant that the claims were in time. The FTT held that it did. The legislation was clear, and excluded enquiries into certain returns (those that had been amended so as to include a capital allowances claim) from the extension of the time limit. Accordingly, the taxpayer’s claims in the present case had been made in time.

Rory Mullan speaking on Capital Gains Tax in 2018

Rory Mullan presented a webinar on Capital Gains Tax in 2018 for Tolley Lexis Nexis on 8 May 2018.

In the webinar (details of which can be access here) he discussed recent and potential legislative and case law development relating to capital gains tax.

Joining Old Square Tax Chambers as an Established Practitioner

We welcome and invite applications to join Chambers from silks or juniors with five or more years revenue law experience, whether currently in independent or employed practice and from solicitors wishing to transfer to the Bar.

Applications should be in writing enclosing a short introductory letter and curriculum vitae to: Rory Mullan at

The closing date for applications for tenancy is 2nd July 2018 at 4.00pm.

Applications for Third Six Pupillage

Old Square Tax Chambers is inviting applications for third six pupillage from candidates with experience in the commercial and/or chancery fields. The pupillage is offered with a view a tenancy at the end of the six months and will commence in October 2018.

Old Square Tax Chambers is a set specializing in revenue law and any applicant will ultimately be expected to develop their practice in this area. Prior experience is not necessary although a good grounding in general law and an interest revenue law is. Many of our existing tenants have come to Chambers without any prior experience in tax and have gone on to establish themselves in the area.

As we are recruiting from those without prior revenue law experience, the pupillage will largely be non-practicing. As a consequence it comes with an award of £25,000. Furthermore, if the successful applicant is offered tenancy, Chambers will guarantee earnings of £50,000 for the first year of practice.

Applications should be in writing enclosing a short introductory letter and curriculum vitae to: Rory Mullan at

The closing date for applications for third six pupillage is 16th July 2018 at 4.00pm.

Charity Tax Seminar

Etienne Wong and Harriet Brown are speaking for LCM Wealth Management Limited at their Charity Tax Seminar, aimed at Private Client Lawyers, Wealth, Family Office and Tax Advisors, Accountants, Charity Lawyers and large charities & foundations with in-house accounting and tax functions, plus charity Treasurers.

Details about the seminar can be seen here.

Notes Available – Free Seminar – Current issues in offshore tax matters – 3 May 2018

Notes are now available following the Old Square Tax Chambers afternoon seminar on 3 May 2018 where James Kessler QC, Rory Mullan and Ross Birkbeck spoke on Current issues in offshore tax matters.

The seminar timetable can be seen below:

4.15 – 4.50       Rory Mullan spoke on The Requirement to Correct Rulesscope of the obligation and when it arises – consequences of non-compliance – dealing with uncertainty – relying on professional advice to avoid penalties.

4.50 – 5.25       Ross Birkbeck spoke on Domicile of Choice Enquiries – Dealing with enquiries on domicile of choice – enquiry procedure and evidence – responding to requests – Schedule 36 defences – Applications for final and partial closure notices 

5.25 – 6.00       James Kessler QC spoke on F(no.2)A: Professional Bodies Q&As and will address The F(nol.2)A 2017 made important changes to the taxation of foreign domiciliaries.  This lecture will consider the questions and draft answers published by the professional bodies on 27 March: – Q&As Trust protections – Q&As Mixed fund cleansing – Q&As Rebasing and the adjustments to the CGT foreign capital losses election – TAX GUIDE 05/18 CLEANSING OF MIXED FUNDS – PROFESSIONAL BODIES Q&AS


Checking the power ~ Article by Ross Birkbeck

Ross Birkbeck has recently had an article published in the Tax Adviser entitled Checking the power.

A copy of the article can be seen here.

GAAR: A Practical Approach by Patrick Cannon – Third Edition

The latest edition of GAAR: A Practical Approach by Patrick Cannon updates the book to include analysis of the first opinions of the Advisory Panel and the most recent version of HMRC’s GAAR Guidance.

Further updates include a new Chapter 4 covering what might be called the weaponisation of the GAAR by means of the specific GAAR penalty in section 212A FA 2013 and the presumption of carelessness in GAAR related matters for the purposes of inaccuracy penalties in Schedule 24 FA 2007.

A new Chapter 9 has been included to deal with the Penalties for Enablers of Defeated Tax Avoidance regime in Schedule 16, F(No.2)A 2017 which can apply when a scheme has been counteracted by HMRC using the GAAR.

Chapter 3 (Counteraction by HMRC) has been updated for the introduction of provisional counteraction, pooling and binding notices and the generic referral of tax arrangements by FA 2016.

Also included are updates to the text for other relevant developments relating to recent Supreme Court Judgments in UBS AG and DB Group Services -v- HMRC and Murray Group Holdings.

A copy of the book can be purchased here.