Amy Mannion

Tax

Amy is particularly well known for her indirect taxes and duties work.  She is instructed as both leader and junior in all levels of tribunals and up to the Supreme Court and CJEU.  She is particularly sought after in public law cases concerning tax matters, for both HMRC and claimants.

Selected Cases

• Jersey Choice Ltd v HMT [2021]: Successful in Court of Appeal and High Court strike out of claim for Francovich damages.
• OWD Ltd and another v HMRC  [2019] UKSC 30: Concerns the HMRC-managed Alcohol Wholesalers Registration Scheme (AWRS).
• Richard Allen v HMRC UKT (2019): High Court upheld that VAT Directive 83/181 art.1 did not confer rights on individuals.
• Beehive Wine Store v HMRC: acted for HMRC in alcohol excise WOWGR-approval revocation appeal.
• R (oao X Ltd & Y Ltd; ABC Ltd) v HMRC [2017]: Court of Appeal consideration of the correct approach to injunctive relief in cases where there is dedicated appeal scheme before the Tribunal which does not provide for suspensive relief. Arises out of new Alcohol Wholesalers Registration Scheme.
• Volkswagen Financial Services (UK) Ltd v HMRC [2017] UKSC 26: Supreme Court determined second ground of appeal and referred primary ground to the CJEU. VAT case; concerns partial exemption special methods. Led by Owain Thomas QC.
• Safe Cellars v HMRC [2017]: High Court discharged injunction against HMRC.
• HMRC v Ahmed, T/A Beehive Wines [2017]: Upper Tribunal review of approach taken by First Tier Tribunal to reviews of reasonableness of a decision.
• HMRC v Brobot Petroleum [2016] UKUT 398: Upper Tribunal decision concerning deferred payments of duty for petroleum. The UT found HMRC had been entitled and reasonable to focus on eligibility as a first stage nt he application process.
• R (oao Ahmed) v HMRC [2015] 3954: HMRC’s WOWGR revocation decision was not ‘fundamentally unlawful’ such that injunctive relief would be appropriate.
• Colchester v HMRC [2014] STI 871: Upper Tribunal.  First UT authority on when a construction is an ‘annex’ to a building.