Old Square Tax Chambers

Philip Simpson KC

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Philip Simpson KC

Philip Simpson KC

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Call: 2001 Silk: 2014

"Philip presents complicated arguments in a thorough and sophisticated matter. It is clear he commands respect from the court."

Chambers and Partners - 2024
  • Whether enforcement of judgment by High Court against assets located in England and Wales would count as remittance of profits from which the debt sued for had derived.
  • Structure to remit clean element of capital receipt on sale of shares listed in New York to UK, avoiding remittance of any element of the capital gain on the sale, where shares held by offshore trust and beneficiary within s.87 TCGA92.
  • VAT in relation to hire-purchase of machinery where lessee in administration.
  • Whether liquidation of separate LLPs and transfer of businesses into a new company within transactions in securities rules.
  • Whether expired credits under mobile phone contract liable to VAT.
  • Whether postponing capital entitlements of beneficiaries entitled to interests in possession terminated their interests in possession for purposes of IHT on trusts.
  • Whether furnished holiday letting arrangements counted as ‘investment’ for purposes of business property relief from IHT.
  • VAT treatment of volume discounts paid by brewery companies to pub where discount included barrelage of tenants / investee companies of recipient of supply.
  • Validity of unauthorised payments charge, unauthorised payments surcharge, and scheme sanction charge on loans made by pension fund to sponsoring employer company.
  • Location of insurance risk for purposes of insurance premium tax.
  • Charities relief from LBTT where charity co-invested with commercial investor.
  • Capital gains tax where disposals set aside by court following contested litigation between parties to the disposals.
  • Claim to income tax relief on losses made on shares in private company.
  • Principal private residence relief where outbuilding sold separately to main building.
  • Whether dilapidations payments capital or income in landlord’s hands.
  • Whether company entitled to deduction against revenue profits in context of share scheme to remunerate director.
  • Drafting / interpretation of tax warranties and indemnities in share purchase agreements.
  • Liability of Delaware corporation to UK taxes in context of aircraft repairs.
  • Structure for taking residential property out of property development company.
  • Structure for winding up a farming company.
  • Structure for de-merging farming / property partnership.
  • Whether purchases of a number of premises related for SDLT purposes.
  • Liability for customs duties where goods stolen after leaving bonded warehouse.
  • VAT bad debt relief in context of liquidation of property development companies.
  • Zero-rating for VAT of supplies obtained in course of construction of residential home.
  • Reduced-rating for VAT of supplies of energy-saving materials.
  • Partial exemption special method for construction of golf clubhouse.
  • Whether property development transaction a joint venture for VAT purposes.
  • Validity of VAT invoices.
  • Identity of parties to supply of refined oil product in context of financing arrangements.
  • Whether trade organisation entitled to exemption on subscriptions as representative body.
  • Whether damages for breach of contract deductible from estate for IHT purposes.
  • Variation of trusts following FA 2006 changes to inheritance tax regime.
  • Establishment of disabled person’s trust in context of a personal injury award.
  • Tax treatment of assignations of life policies written in trust.
  • Effect of precatory gift for inheritance tax purposes.
  • Validity of deed of variation / nil-rate band discretionary trust.
  • Tax-efficient structure for payment of school fees.
  • Special annual allowance charge for pension contributions.
  • Domicile of individuals.

"Philip presents complicated arguments in a thorough and sophisticated matter. It is clear he commands respect from the court."

Chambers and Partners - 2024

"He is helpful, commercial and technically very strong."

Chambers and Partners - 2022

"Very good with clients"

Chambers and Partners - 2022

"Encyclopedic knowledge of tax law"

Chambers and Partners - 2017

  • Visiting lecturer in tax law, University of Aberdeen: 2012
  • Traineeship with Dickson Minto, spending two years doing M&A work
  • Legal Assistant to the Lord President before devilling to become an advocate
  • Regular papers on tax topics

  • Appointed QC (Scotland) 2014
  • Called to both the Scottish and English bars: 2001
  • CTA-qualified tax advocate
  • Standing Junior to the Department of Work and Pensions: 2012 – 2015
  • The Attorney General’s A Panel of Junior Counsel to the Crown

Philip Simpson KC is regulated by the Bar Standards Board

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Barrister page printed on 10:55:pm 23 April 2024 - Visit https://www.taxchambers.com/barristers/philip-simpson-qc/ for the latest version of this page.