Harriet Brown
Harriet is qualified to practice in England and Wales and Jersey. She appears in courts and tax tribunals regularly. She advises in relation to direct and indirect taxes, frequently in the context of individuals and trusts. Additionally, she has particular expertise in international matters such as double tax treaties, TIEAs, FATCA/CRS disclosure facilities and conflict of laws issues arising in a tax context.
Harriet is also experienced in resolving disputes with HMRC. Her approach is always to give detailed and practical advice from the initial enquiry through to any tribunal hearing, which often results in a favourable conclusion at an early stage and always aims to achieve a quick and cost-effective solution.
Harriet’s Jersey practice primarily involves advising on Jersey trusts and tax in Jersey. She has particular expertise in relation to trust remedies in Jersey (including the statutory mistake and “Hastings-Bass” regimes) and Jersey income tax.
Harriet is licensed to accept instructions under the Public Access Scheme.
Typical matters on which Harriet has been asked to advise include the following:
- HMRC enquiries involving domicile, the transfer of assets abroad, HMRC’s powers of recovery outside the UK, employment taxes and taxation of charities.
- Employee taxation including the scope of the benefits code, the disguised remuneration legislation (Part 7A ITEPA 2003) and the Rangers case.
- Pensions taxation, including taxation of international pensions (QROPS) and all elements of UK-based pensions taxation (FA 2004, Part 4).
- Non-resident trusts.
- Residence, domicile and the taxation of foreign domiciliaries.
- Inheritance tax planning.
- Taxation of charities and gifts to charities.
- FATCA and CRS.
- Paul Harrison v HMRC [2023] UKUT 00038 (TCC)
- Coconut Animated Island Ltd v Revenue and Customs Commissioners [2022] UKFTT 303 (TC)
- CHF Pip! Plc v HMRC [2021] UKFTT 383 (TC)
- Butt v HMRC [2019] EWCA Civ 554 (Court of Appeal)
- Wallace v HMRC
- HMRC v Hely-Hutchinson [2017] EWCA Civ 1075
- Dong v National Crime Agency
- Chadda v Revenue and Customs Comrs
- Fisher v HMRC
- Freeman v HMRC
- Ballard v HMRC
- Re A
- Countrywide Estate Agents FS Limited v HMRC
- H v H
- Harriet Brown and Rebecca Sheldon represent Appellant pro bono
- Designing The Perfect International Tax System
- Webinar on Crypto Asset Reporting Framework - New Challenges for Crypto Businesses
- Legal Directory 2024 Bar Rankings
- Harriet Brown admitted as a Fellow of the Chartered Institute of Taxation
- Chambers High Net Worth 2023
- Legal 500 - Shortlist 2023
- The Legal Training Consultancy ‘Tax Planning for High-Net-Worth Individuals’ online conference
- TaxSnax – Episode 11: When is a penalty payable for tax errors
- Chambers and Partners UK Bar Awards 2022
- Chambers seminar on Taxation of Employment Income: Recent developments
- Harriet Brown speaking in International Tax Bites Christmas Bonus Episode
- Old Square Tax Chambers ranked in Chambers and Partners for the UK Bar 2022
- In the matter of CHF Pip! Plc v HMRC – Judgement –
- Harriet Brown and Grahame Jackson on information exchange and tax podcasts
- Harriet Brown’s Book on International Tax Agreements now available
- Chambers and Partners – High Net Worth Guide 2021
- Success in Jersey Royal Court
- TaxSnax – Episode 5: Freeports
- Old Square Tax Chambers launches ’TaxSnax’
- International Tax Bites launches with Harriet Brown
- Taxation of Internationally Mobile Employees
- Legal 500 2021 Rankings
- Ranked as a leading set in Chambers HNW
- Double Tax Treaties Explained
- Current Issues in Employment Taxation
- Free Seminar on Private Client Tax Developments
- Old Square Tax Chambers ranked as a leading set
- Old Square Tax Chambers ranked in Chambers and Partners
- 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: Taxation of Trusts
- Tax Planning for 2019 – Key Haven Publications Ltd
- Surprise Discovery – Tax Adviser, March 2016
- DEEMED DIVIDENDS, ZERO/TEN, JERSEY AND THE EU
- The Transparency of Jersey Partnerships and Certainty when Planning
- The Changing Face of Taxation in a Low Tax Jurisdiction
- Littlewoods Ltd and others v HMRC: compound interest overpaid VAT – where are we now?
- Correcting Mistakes: Ashcroft v Barnsdale and rectification
- The Development of Hastings-Bass in Jersey
- Queensbury Rules – the HMRC Internal Review Procedure One Year On
- Charities and variation of wills
- Considering the UK Tax Implications for Jersey Foundations
- TaxSnax: Spring Budget 2024
- Tax Snax - Episode 16: Cosmetic Surgery
- Key Haven 2024 - PRACTICAL TAX PLANNING 2023
- Hybrid seminar on Tax Planning Through Trusts
- TaxSnax – Episode 13: Penalties & Human rights
- Webinar on The Crypto Asset Reporting Framework
- DAC6 and MDR: What To Do Now
- UK Property Taxation: What You Need to Know Now
- Old Square Tax Chambers launches TaxSnax
- TaxSnax – Episode 5
- Taxation of Trusts
- Private Client Tax Developments
- Current Issues in Employment Taxation
- Taxation of Internationally Mobile Employees
- DAC6 and MDR: What To Do Now
- 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
- Jersey Law of Trusts (Key Haven Publications 2013)
- The Interaction of the EU Treaty and UK Tax Code (with Rory Mullan) (Key Haven Publications 2013)
- Current contributing author to Tolley’s Property Taxation, Bloomberg Indirect Tax Navigator, CCH’s Tax Planning and the Tilley & Collison UK Tax Guide
- Former co-author of the Taxation of Charities (7th Edition, Key Haven Publications 2011)
- FATCA/CRS and tax information exchange agreements
- Residence under the statutory residence test and domicile
- Double tax treaties
- Tax planning for non-UK resident and domiciled individuals
- The residence nil rate band
- Capital gains tax including case law and ATED related gains
- Employment taxation
- The administration and application of the GAAR, and the HMRC GAAR guidance
- Tax avoidance, acceptable tax planning, capital gains tax targeted avoidance provisions and the general anti-abuse provision
- Inheritance tax planning, including the relevant property regime, and the use of APR and BPR
- Member of the Chartered Institute of Taxation
Harriet Brown is regulated by the Bar Standards Board