As leader of the Fieldfisher contentious tax team, I wear several hats. I work with my fellow partners and with clients to scope tax issues, and design and implement strategies for resolving them. I manage a team of ten fantastic and high performing solicitors and barristers, together with two trainees, across our London and Birmingham offices, and I am constantly on the hunt for new talent. We work with all kinds of taxpayers, across all types of taxes, on investigations, technical disputes, and on professional negligence. We have worked on over a hundred separate engagements in the last year.
If you could make one change to tax, what would it be?
I’d properly staff and fund the First-tier Tribunal’s administrative function. First-tier Tribunal Chamber President Greg Sinfield spoke in Tax Journal (10 May 2023) about the difficulties caused by HMRC poaching his administrative staff. It causes frustration and delay for court users and distress and expense for taxpayers. On one case I am handling at the moment, it took five months for the First-tier Tribunal to assign a case number; and another four months for it to approve some (agreed!) directions. On a recent weekend, I went to Salisbury Cathedral to look at one of the surviving copies of Magna Carta. It was unexpectedly moving to see. One sentence (which is still good law) reads ‘nulli vendemus, nulli negabimus, aut differemus, rectum aut justiciam’: ‘we will not sell, or deny, or delay right or justice to anyone.’ I think that the delays are now so severe that this principle is in danger.
What do you know now that you wish you’d known at the start of your career?
That it was all going to be okay. I finished the Legal Practice Course in 1998, at the time of a significant slowdown in legal services, and was unable then to find a training contract. The next three years were a struggle. The life skills I learned during that period have since been valuable. But I had no emotional support network; in the days before internet use became widespread, it was very difficult to find people in the same situation with whom to compare experiences, so it was a lonely and difficult time. Then, in 2001, I became a fast stream civil servant in the Inland Revenue and entered the world of tax. I am still in contact with some of the people I met then, including my old Revenue tutor, John McDonough, who I see regularly. The technical skills he taught me on the inspector training course I use every working day.
What issues have been clients been raising recently?
In terms of new matters coming in – heavyweight disclosures relating to offshore income; and disputes about aggregates levy, plastic packaging tax, and pensions unlocking charges. In terms of what we’ve resolved recently – agreeing a £15m follow-on offshore disclosure with HMRC with no penalties charged; resolving an £18m PAYE and NICs dispute for £nil; and settling a number of multi-million pound professional negligence claims.
And finally, you might not know this about me but...
I am fascinated by the social impacts of taxation. By way of example, I am the current president of the Wine Label Circle, the international society for collectors of silver decanter labels. In the eighteenth and early nineteenth century most wine came into the country, and was sold, in barrel – either to licensed premises or to those who could afford to buy in bulk. From barrel, in licensed premises, it was put into jugs for service; in the cellars of the middle classes, it was put into decanters. Decanter labels enabled the wines served in the latter circumstance to be identified. William Gladstone, as chancellor, made significant changes to the duty and licensing regime in 1861. The Single Bottle Act meant that wine could be sold in bottle for consumption off the premises. This led to the creation of the off-licence trade. It also led to the decline of the decanter label – because the single bottles sold bore paper labels identifying the contents. But the decanter labels that were made, remain, and are affordable examples of the work of even the great silversmiths of the day.
As leader of the Fieldfisher contentious tax team, I wear several hats. I work with my fellow partners and with clients to scope tax issues, and design and implement strategies for resolving them. I manage a team of ten fantastic and high performing solicitors and barristers, together with two trainees, across our London and Birmingham offices, and I am constantly on the hunt for new talent. We work with all kinds of taxpayers, across all types of taxes, on investigations, technical disputes, and on professional negligence. We have worked on over a hundred separate engagements in the last year.
If you could make one change to tax, what would it be?
I’d properly staff and fund the First-tier Tribunal’s administrative function. First-tier Tribunal Chamber President Greg Sinfield spoke in Tax Journal (10 May 2023) about the difficulties caused by HMRC poaching his administrative staff. It causes frustration and delay for court users and distress and expense for taxpayers. On one case I am handling at the moment, it took five months for the First-tier Tribunal to assign a case number; and another four months for it to approve some (agreed!) directions. On a recent weekend, I went to Salisbury Cathedral to look at one of the surviving copies of Magna Carta. It was unexpectedly moving to see. One sentence (which is still good law) reads ‘nulli vendemus, nulli negabimus, aut differemus, rectum aut justiciam’: ‘we will not sell, or deny, or delay right or justice to anyone.’ I think that the delays are now so severe that this principle is in danger.
What do you know now that you wish you’d known at the start of your career?
That it was all going to be okay. I finished the Legal Practice Course in 1998, at the time of a significant slowdown in legal services, and was unable then to find a training contract. The next three years were a struggle. The life skills I learned during that period have since been valuable. But I had no emotional support network; in the days before internet use became widespread, it was very difficult to find people in the same situation with whom to compare experiences, so it was a lonely and difficult time. Then, in 2001, I became a fast stream civil servant in the Inland Revenue and entered the world of tax. I am still in contact with some of the people I met then, including my old Revenue tutor, John McDonough, who I see regularly. The technical skills he taught me on the inspector training course I use every working day.
What issues have been clients been raising recently?
In terms of new matters coming in – heavyweight disclosures relating to offshore income; and disputes about aggregates levy, plastic packaging tax, and pensions unlocking charges. In terms of what we’ve resolved recently – agreeing a £15m follow-on offshore disclosure with HMRC with no penalties charged; resolving an £18m PAYE and NICs dispute for £nil; and settling a number of multi-million pound professional negligence claims.
And finally, you might not know this about me but...
I am fascinated by the social impacts of taxation. By way of example, I am the current president of the Wine Label Circle, the international society for collectors of silver decanter labels. In the eighteenth and early nineteenth century most wine came into the country, and was sold, in barrel – either to licensed premises or to those who could afford to buy in bulk. From barrel, in licensed premises, it was put into jugs for service; in the cellars of the middle classes, it was put into decanters. Decanter labels enabled the wines served in the latter circumstance to be identified. William Gladstone, as chancellor, made significant changes to the duty and licensing regime in 1861. The Single Bottle Act meant that wine could be sold in bottle for consumption off the premises. This led to the creation of the off-licence trade. It also led to the decline of the decanter label – because the single bottles sold bore paper labels identifying the contents. But the decanter labels that were made, remain, and are affordable examples of the work of even the great silversmiths of the day.
