Sarabjit Singh KC

Tax

Sab has appeared in numerous landmark cases over the last few years. These include the British Film Institute litigation on the VAT cultural exemption that went to the European Court of Justice, appearing as sole counsel in the Amoena appeal which is the only ever customs case to have gone to the House of Lords or Supreme Court, acting as lead counsel in the seminal rating case of Newbigin v Monk in the Supreme Court and appearing again in the Supreme Court in the major VAT case of SAE Education Ltd. Sab primarily acts for taxpayers against HMRC on liability issues in a wide range of cases across multiple sectors, and often successfully challenges HMRC’s approach before a case has got anywhere near a court or tribunal.

Sab is recommended as leading silk in tax by both Chambers & Partners and the Legal 500. Recent editorial includes:

“Sarabjit distils very complicated concepts into easy-to-digest snippets that we can understand in a practical way. He commands the respect of opponents and judges.” Chambers & Partners 2026

“Sarabjit is a formidable KC. I am impressed by his ability to lay out a clear strategy and also adapt to changing circumstances.” Chambers & Partners 2026

“Sab is an exquisite choice of barrister for both technical tax matters and questions of public law. Highly recommended and astute.” Legal 500 2026

“His written arguments are very on-point and he’s always up to speed with the latest developments in the law.” Chambers & Partners 2025

“He is responsive, knowledgeable and approachable.” Chambers & Partners 2025

“An incredible advocate and tactician.  He provides hands-on and easy to digest advice on the substantive elements of a case and overall litigation strategy.” Legal 500 2025

Selected Cases

Tax & Duties

• Charge My Street Ltd v HMRC [2026] UKFTT 318 (TC): Succeeded on behalf of taxpayer in lead case on VAT liability of charging of electric vehicles in public places, with tribunal accepting that such supplies (below a certain level) are subject to the reduced rate of VAT applicable to supplies of electricity; case of great interest and impact in EV charging sector generally.
• R (Countryside Properties (UK) Ltd) v HMRC (2026): acting for taxpayer in judicial review claim alleging that HMRC failed to follow guidance and acted irrationally in refusing to waive interest charge on corporation tax held by them after due date. Granted permission to apply for judicial review on all grounds.
• R (Hotelbeds UK Ltd) v HMRC [2025] EWHC 2312 (Admin): Successfully acted for taxpayer in judicial review claim against HMRC challenging HMRC’s refusal to repay taxpayer millions of pounds in input tax because VAT invoices were not available; High Court judge held that the ‘only lawful decision’ on the facts of the case was for HMRC to repay the taxpayer.
• Food liability and VAT (2025): Acting for various taxpayers in food liability VAT cases challenging HMRC’s failure to zero rate particular products.
• CCHG Ltd v HMRC (2025): Acting for taxpayer in high value appeal against HMRC’s refusal to accept that vapes are pharmaceutical products designed to help people stop smoking tobacco and should therefore be subject to the reduced VAT rate.
• HMRC v Gray & Farrar International LLP [2023] EWCA Civ 121: Succeeded before Court of Appeal in VAT case on place of supply of services of a high-end matchmaking agency, which established the existence in English law of a ‘predominant element test’ when characterising single supplies.
• Mainpay Ltd v HMRC [2022] EWCA Civ 1620: Succeeded as lead counsel in Court of Appeal on whether a supply was of exempt medical care.
• HMRC v Kishore [2021] EWCA Civ 1565: Acted as lead counsel in case in the Court of Appeal on the correct approach in the tax tribunal to abuse of process and Article 6 of the ECHR in the context of a previous struck out appeal.
• X Inc (2021): Acted for US-based taxpayer on application of VAT welfare exemption to supplies made in UK.
• Claims Advisory Group Limited v Revenue and Customs [2021] UKUT 199 (TCC): Acted in case on whether fee received for recovery of overpaid PPI fell within the VAT insurance exemption.
• Malca-Amit (UK) Ltd v HMRC [2021]: Acted as sole counsel for taxpayer in appeal concerning liability to duty on significant importation of rough diamonds.
• Sporting Wholesale Ltd v HMRC [2021]: Acted as sole counsel for taxpayer in multi-pronged attack on HMRC for repeated interceptions of company’s goods for no proper reason; case involved simultaneous judicial review, human rights and statutory challenges against HMRC.
• SAE Education Ltd v HMRC [2019] UKSC 14: Appeared as sole counsel for HMRC in the Supreme Court in case about what an entity needs to show to establish that it is a college ‘of’ a university for the purposes of the VAT education exemption.
• Case C-592/15, Commissioners for HMRC v British Film Institute [2017] STC 681: Successfully appeared before the Court of Justice of the European Union in case about whether Member States are permitted to choose which cultural services to exempt for the purposes of applying the cultural exemption from VAT.
• Amoena (UK) Ltd v HMRC [2016] UKSC 41, [2016] 1 WLR 2904:Appeared as sole counsel for the Revenue in the Supreme Court in customs duty case on the meanings of ‘part’ and ‘accessory’.
• South African Tourist Board v HMRC [2014] UKUT 280 (TCC), [2014] STC 2650: Succeeded in appeal on the issue of whether a tourist board owned by the South African government was making supplies of marketing services for consideration to the government.
• Vehicle Control Services Ltd v HMRC [2013] EWCA Civ 186, [2013] STC 892: Appeared before Court of Appeal in case on whether charges collected by a parking enforcement company were outside the scope of VAT as either damages for breach of contract or damages for trespass.
• British Association of Leisure Parks, Piers & Attractions Ltd v HMRC [2013] UKUT 130 (TCC): Successfully appeared before the Upper Tribunal (Tax and Chancery Chamber) on the issue of whether a trade association’s primary purpose was political lobbying and whether it would be unjustly enriched by the repayment of output tax.
• Tui Travel PLC & Ors v HMRC [2013] UKFTT 75 (TC): Successfully acted in claim by travel agents for repayment of approximately £150 million in VAT allegedly overpaid on commissions received from tour operators for selling package holidays.
• R (Checkprice (UK) Ltd (In Administration)) v HMRC [2010] EWHC 682 (Admin), [2010] STC 1153: Acted for claimants in judicial review challenge to the actions of HMRC in detaining perishable goods without seizing or releasing them and then destroying them.
• Holland (t/a the Studio Hair Company) v HMRC [2008] EWHC 2621 (Ch), [2009] STC 150 & HMRC v Denyer [2007] EWHC 2750 (Ch), [2008] STC 633: Successfully appeared in two appeals to the Chancery Division of the High Court on the issue of whether certain supplies were supplies of land for VAT purposes.

Rating & Valuation

• R (Fisheries London Ltd) v HMRC (2026): acting for serviced office ratepayer in judicial review claim alleging that VOA breached its legitimate expectation, acted irrationally and failed to follow guidance in merging its premises. Granted permission to apply for judicial review on all grounds.
• Hughes (VO) v Exeter City Council [2020] UKUT 7 (LC): Acted in major case on whether loss-making museums should in effect pay no non-domestic rates.
• Newbigin (VO) v SJ & J Monk (a firm) [2017] UKSC 14, [2017] 1 WLR 851: Appeared in Supreme Court as leading counsel in case on rateability and valuation of non-domestic buildings undergoing reconstruction; reported below at [2015] EWCA Civ 78, [2015] 1 WLR 4817.
• Tunnel Tech Ltd v Reeves (VO) [2015] EWCA Civ 718: Succeeded before the Court of Appeal on the question of whether a hereditament was a ‘market garden’ for the purposes of the agricultural exemption and on the issue of whether buildings could fall within the exemption for agricultural land.
• Johnson (VO) v HB Foods Ltd [2013] UKUT (LC) 539: Appeared before President of the Upper Tribunal (Lands Chamber) in case about whether appeals before the Lands Chamber are heard de novo.