Rory Mullan KC
Rory Mullan KC enjoys advising and representing taxpayers on range of both direct and indirect tax matters. His aim is always to ensure the best outcome while recognising the practical and commercial realities for those facing difficult tax issues.
Issues Rory has recently dealt with in the course of his practice include:
- Taxation of offshore structures, including the application of the transfers of assets abroad code, the attribution of gains under section 13 TCGA 1992 and the treatment of trust gains under sections 86 and 87 TCGA 1992.
- Taxation of trusts.
- Residence and domicile status.
- Taxation of non-UK domiciled persons and those who are deemed to be UK domiciled.
- The application of the Transactions in Securities legislation.
- Loan relationships.
- R&D relief.
- Employee taxation including the scope of the benefits code, the employment related securities legislation (Part 7 ITEPA 2003) and the disguised remuneration legislation (Part 7A ITEPA 2003).
- Compatibility of direct tax provisions with EU law.
- The DOTAS regime.
- Accelerated Payment Notices and Follower Notices.
- The GAAR and its application.
- Advising on transfer of residence relief.
- Appeals in relation to a demand for import duty.
- Advice in relation to a HMRC decisions in respect of export declarations.
Rory is a member of the Revenue Bar Association, the Chancery Bar Association and the Stamp Taxes Practitioners Group. He is also qualified as a Chartered Tax Adviser. Rory is licensed to accept instructions under the Public Access Scheme.
- The App Accounting Group Ltd, Uberdev Ltd & Rosetta Software Ltd v HMRC [2024] UKFTT 100 (TC) (TC09051)
- Fisher v HMRC [2023] UKSC 44
- Revenue and Customs Commissioners v AML Tax (UK) Ltd and another [2022] UKFTT 174 (TC)
- Asset House Piccadilly Ltd v Revenue and Customs Commissioners [2023] UKFTT 385 (TC)
- Swiss Centre Ltd v Revenue and Customs Commissioners [2023] UKFTT 449 (TC)
- Hoey v Revenue and Customs Commissioners; Regina (Hoey and others) v Revenue and Customs Commissioners - [2022] 1 WLR 4113
- R (on the application of Sibley) v Revenue and Customs Commissioners - [2022] STC 336
- Revenue and Customs Commissioners v Smartpay Ltd and another - [2022] SFTD 1010
- Laing O'Rourke Services Ltd v Revenue and Customs Commissioners; Willmott Dixon Holdings Ltd v Revenue and Customs Commissioners - [2023] STC 1333
- Redmount Trust Company Ltd v HMRC [2023] UKUT 68 (TCC) (Upper Tribunal)
- Hoey v HMRC [2022] EWCA Civ 656 (Court of Appeal)
- Willmott Dixon Holdings Ltd v HMRC [2022] UKFTT 6 (TC)
- A D Bly Groundworks and Civil Engineering Ltd & CHR Travel Ltd v HMRC [2021] UKFTT 445 (TC)
- HMRC v Fisher [2021] EWCA Civ 1438
- lamp & Anor, R (On the Application Of) v HMRC [2021] EWHC 2360 (Admin)
- Butt v HMRC [2019] EWCA Civ 554 (Court of Appeal)
- R (Jimenez) v FTT & HMRC [2019] EWHC Civ 51 (Court of Appeal)
- Routier v HMRC [2017] EWCA Civ 1584 (Court of Appeal)
- HMRC v Hely-Hutchinson [2017] EWCA Civ 1075
- HMRC v Apollo Fuels Ltd [2016] EWCA Civ 157 (Court of Appeal)
- Revenue and Customs Comrs v PA Holdings Ltd [2011] EWCA Civ 1414 (Court of Appeal)
- Revenue and Customs Commissioners v Loyalty Management UK Ltd [2008] STC 59, [2007] EWCA Civ 965, and 151 Sol Jo 1300
- Greenalls Management Ltd v Customs & Excise Commisssioners [2005] UKHL 34 (House of Lords)
- Howell v Trippier [2004] STC 1245 (Court of Appeal)
- Red Discretionary Trustees v Inspector of Taxes; Spc 397 [2004] STC (SCD) 132
- The GATA Gibraltar Tax Essay Prize
- Boox company successfully applies to join clients' appeals against MSC charge
- Legal Directory 2024 Bar Rankings
- Chambers High Net Worth 2023
- TENANCY AND THIRD SIX PUPILLAGE VACANCY
- TENANCY AND THIRD SIX PUPILLAGE VACANCY
- Redmount Trust Company Ltd v HMRC – voluntary returns effective for SDLT purposes
- The Legal Training Consultancy ‘Tax Planning for High-Net-Worth Individuals’ online conference
- Chambers and Partners UK Bar Awards 2022
- Chambers seminar on Taxation of Employment Income: Recent developments
- Court of in Hoey v HMRC
- Willmott Dixon Holdings Ltd v HMRC – successful claim.
- Rory Mullan to be appointed Queens Counsel
- DECISION ON CORPORATION TAX FOR PROVISION IN RESPECT OF UNFUNDED PENSION
- DECISION ON CORPORATION TAX FOR PROVISION IN RESPECT OF UNFUNDED PENSION
- Redmount Trust Company v HMRC – decision on SDLT sub-sale by option agreement
- Old Square Tax Chambers ranked in Chambers and Partners for the UK Bar 2022
- Rory Mullan formally sworn in as Queen’s Counsel
- HMRC v Fisher Judgement
- TENANCY AND THIRD SIX PUPILLAGE VACANCY
- Chambers and Partners – High Net Worth Guide 2021
- Capital Gains Tax (2021)
- Rory Mullan QC interviewed by the Tax Journal
- Rory Mullan QC article for the Tax Journal
- Chambers Webinar – Contractor Loan Schemes
- Contractor loans, PAYE and transfer of assets abroad
- Allocation of profits of mixed partnerships – HFFX LLP v HMRC
- Recent Supreme Court Tax Cases
- Legal 500 2021 Rankings
- Ranked as a leading set in Chambers HNW
- Rory Mullan: Tax Penalties Uncovered – Key Elements Explained
- Rory Mullan comments on Loan Charge decision
- Fisher v HMRC
- Private Client Tax – End of year round-up 2019
- Current Issues in Employment Taxation
- Old Square Tax Chambers ranked as a leading set
- 2019 Chambers UK Bar Awards
- Old Square Tax Chambers ranked in Chambers and Partners
- Free Seminar (Manchester) – Dealing with HMRC Investigations
- Tax for General Practice – Spring 2019
- James Kessler QC and Ross Birkbeck – Embiricos v HMRC [2019]
- Rory Mullan and Harriet Brown – Butt v HMRC
- Free Seminar: Tax Administration and Taxpayer Rights
- Tax Planning for 2019 – Key Haven Publications Ltd
- Non-Doms after the Budget
- Key Haven 2024 - PRACTICAL TAX PLANNING 2023
- Free Seminar - Tax Incentives for R&D: Recent Developments
- Tax Administration and Taxpayer Rights
- Dealing with HMRC Investigations
- Current Issues in Employment Taxation
- Recent Supreme Court Tax Cases
- Contractor Loan Schemes
- Key Haven Publications 2022 – 40th Annual Oxford Four-Silk Sixteen-Speaker
- Key Haven Publications 2021 – 39th Annual Oxford Four-Silk Fourteen-Speaker Residential Seminar
- Key Haven Tax Planning Webinar
- KEY HAVEN PUBLICATIONS LTD – PRACTICAL TAX PLANNING 2019
- The Interaction of EU Treaty Freedoms and the UK Tax Code with Harriet Brown, (Key Haven Publications 2011)
- Author of chapter on Capital Gains Tax in Tolley’s Property Taxation
Topics on which Rory has recently lectured include:
- Key concepts relating to R&D Relief
- The taxation of Offshore Funds
- Inheritance Tax and Domicile
- Inheritance tax home loan arrangements
- Employee trusts
- The concept of “earnings” for income tax and NICs
- Issues for Foregin Domiciliaries
- Transfer of Assets Abroad
- Capital gains tax
- The recent changes to taxation of non-doms
- Silk in 2021
- Called to the Grays Inn Bar in 2000
Rory Mullan KC is regulated by the Bar Standards Board