Christopher Vallis

Christopher brings nearly a decade of experience working in HMRC’s legal department and has a proven track record before the Tax Tribunals. He is regularly instructed in disputes with HMRC, appearing in appeals before the First-tier and Upper Tribunals, drawing on his detailed understanding of HMRC and Tribunal processes and procedures.

Alongside his disputes practice, Christopher has a broad advisory practice, acting for individuals, trustees, owner-managed businesses and corporate clients across a range of tax matters.

Recent matters include:

• Inheritance Tax (IHT), including charitable dispositions and business property relief
• Gifts with reservation of benefit (GWR)
• Pre-owned asset tax (POAT)
• The Double Taxation Relief (Estate Duty) Pakistan Order 1957
• Enterprise Investment Scheme (EIS) relief claims
• The Constriction Industry Scheme (CIS)
• Research & Development (R&D) relief
• Pension schemes, including scheme sanction charges and the lump sum death benefit allowance
• Part 7A ITEPA (disguised remuneration)
• Corporation Tax disputes
• Stamp Duty Land Tax (SDLT) issues, including mixed-use, “gardens and grounds”, and “dilapidated property” cases
• Statutory Residence Test (SRT)
• The tax consequences of an individual’s move to Dubai, UAE
• An appeal to the UT in respect of a late appeal and procedural issues
• Appeals to the FTT in respect of VAT
• An appeal to the FTT in respect of SDLT
• An appeal to the FTT in respect of CIS

Disputes, compliance, and procedure:

• Alleged deliberate behaviour
• Joint and several liability notices, including alleged phoenixing
• HMRC enquiries, closure notices, and assessments
• Schedule 36 information notices
• Penalties and suspension (carelessness, reasonable excuse, notification)
• Procedural and jurisdictional issues, including late appeals and the availability of public law defences and estoppel
• Code of Practice 9 (COP 9)
• HMRC claims
• The general anti-abuse rule (GAAR)
• ADR

Christopher is qualified to accept instructions from the public and can be contacted directly via email or via the clerks.

Christopher is a member of the Attorney General’s London C Panel.