Edward Waldegrave

Tax

Edward’s tax practice covers litigation and advice across all areas of direct and indirect tax. His practice spans both personal and business taxes, and the cases on which Edward is instructed are often complex, high-value, and/or involve important points of principle. He is recommended as a leading junior by both Chambers & Partners and the Legal 500. Recent editorial includes:

“Edward writes beautifully and fluently and is super with clients. He’s very articulate and very reliable – just everything you could ever want in a junior.”
Chambers & Partners 2026

“Edward Waldegrave is bright, diligent and sharp-witted.”
Chambers & Partners 2026

“He is particularly good at explaining complex matters to clients and at advocacy. Edward is someone who’s very good to work with, because you genuinely have a very collaborative discussion with him.”
Chambers & Partners 2026

“Edward Waldegrave is bright, hard-working and very capable.”
Chambers & Partners 2026

“Edward is very clear and logical in seeing how a particular analysis falls together.”
Chambers & Partners 2026

“Edward is very personable, knowledgeable, and quick to respond and give his views.”
Chambers & Partners 2026

“Edward operates at a higher level. As a junior, he is absolutely great. He writes really well and he is on top of the details, showing good judgement.”
 Chambers & Partners 2026

“Edward is very capable and assiduous, and very good with clients.”
Chambers & Partners 2026

“Edward is very personable, very knowledgeable and very quick to respond and give his views. He is definitely great at the heavy lifting behind the scenes.”
 Chambers & Partners 2026

“A great cross-examiner, writes brilliantly and so diligent. A joy to work with.”
Legal 500 2026

“He is very bright, he writes beautifully and fluently, and he is super with clients. Very articulate and utterly reliable, he’s just everything you could ever want in a junior.”
 Chambers & Partners 2026

“Edward is very polite and intelligent, and in no way egotistical. He’s quick on the uptake and a skilled advocate.”
Chambers & Partners 2026

“Really good and thorough, a brilliant advocate and cross-examiner. Hugely knowledgeable.”
Legal 500 2026

“A great cross-examiner, writes brilliantly and so diligent. A joy to work with.”
Chambers & Partners 2025

“He is very quick to turn things around, and both thorough and calm under pressure.”
Chambers & Partners 2025

“Edward is simply excellent.  A particular strength is his ability to express complex matters clearly and simply.  Extremely calm.  Excellent client manner.  A pleasure to work with.”
Legal 500 2025

Selected Cases

Direct Tax:

• Swiss Centre Limited v. HMRC – Case concerning the deductibility of a £34 million payment under the “loan relationship rules”. Edward acted as lead counsel for HMRC in the First-tier Tribunal and Upper Tribunal.
• Cobalt Data Centre 2 LLP v. HMRC – Case concerning the availability of enhanced “enterprise zone” capital allowances for expenditure on the construction of data centres. Edward acted for HMRC in the Upper Tribunal, Court of Appeal and Supreme Court.
• Ingenious Film Partners 2 LLP v. HMRC – Long-running and very high-value litigation concerning the tax consequences of investments in films. Edward has acted for the taxpayers at all stages of the litigation, appearing in the First-tier Tribunal, the Upper Tribunal and the Court of Appeal. A discrete issue remains to be considered by the Upper Tribunal.
• Burley v. HMRC – Case concerning the tax consequences of a purported assignment of a right to partnership income, which was determined by the First-tier Tribunal in August 2025 and is on appeal to the Upper Tribunal. Edward acts for HMRC.
• M R Currell Limited v. HMRC – Case concerning the tax consequences of arrangements involving an employee benefit trust. The case is on appeal to the Court of Appeal.
• Mersey Docks and Harbour Company Limited v. HMRC – Case concerning the availability of “plant and machinery” capital allowances for significant expenditure on a quay wall at the Port of Liverpool. The case is on appeal to the Upper Tribunal.

Indirect Tax:

• Barclays Services Corporation v. HMRC – Case concerning VAT grouping in the financial services sector. Edward is also involved in various other cases concerning similar issues, and appeared in the Upper Tribunal in HSBC Electronic Data Processing (Guangdong) Limited v. HMRC. Certain of the cases in this area in which Edward is acting involve claims for judicial review as well as statutory appeals.
• O’Neill Wetsuits Limited v. HMRC – Case concerning the correct classification for customs purposes under the UK Tariff of wetsuits. Edward appeared for HMRC in the First-tier Tribunal and the Upper Tribunal.
• ThyssenKrupp (UK) Limited v. HMRC – Case concerning the availability of “inward processing relief” from customs duty and import VAT. Edward appeared for HMRC in the First-tier Tribunal and the Upper Tribunal.
• Taxpayers v. HMRC – Edward is instructed in high-value litigation in the High Court concerning a claim against the UK for damages said to have been suffered as a result of the UK permitting (until April 2020) “post-duty point dilution” of certain alcoholic beverages. The practice is alleged to have resulted in domestic producers obtaining an unfair advantage over producers based in EU countries.

Rating:

• Moore (Valuation Officer) v. Bailey – Case concerning whether equestrian facilities constituted a single hereditament, or two separate hereditaments, for rating purposes. Edward acted on behalf of the Valuation Officer in an appeal to the Upper Tribunal against the decision of the Valuation Tribunal for England.