Tax & Rating

Tax and rating are a core part of our work, and we have historic and extensive experience across the whole spectrum of tax and rating litigation.

The team is led by Owain Thomas KC and Sarabjit Singh KC and members of chambers have experience in all forms of domestic tribunals from the First-tier Tribunal and Valuation Tribunal to the Supreme Court as well as the CJEU.

1 Crown Office Row was shortlisted for ‘Tax Set of the Year’ at the 2023 Legal 500 Bar Awards and is highly recommended for handling all kinds of tax and rating work.

Recent work handled by the team includes:

• ScottishPower (SCPL) Limited & Ors v HMRC [2025] EWCA Civ 3 – Laura Inglis appeared successfully for the taxpayer in this Court of Appeal case concerning the deductibility of redress payments brokered by an industry regulator.
• R (on the application of Cobalt Data Centre 2 LLP) v. HMRC [2024]: Edward Waldegrave appeared successfully for HMRC in this Supreme Court case concerning the construction of capital allowances legislation, and the general law of contract.
• Jersey Choice Ltd v His Majesty’s Treasury [2024] UKSC 5: Amy Mannion appeared successfully on behalf of His Majesty’s Treasury in this Supreme Court case, a Francovich damages claim, concerning the lawfulness of the UK removing low value consignment VAT relief from goods sold by mail order from the Channel Islands.
• Hippodrome Casino [2024] UKUT 27 (TCC): Matthew Donmall appeared successfully on behalf of His Majesty’s Revenue and Customs in an appeal before the Upper Tribunal Tax and Chancery Chamber about the recovery of residual input VAT tax incurred by Hippodrome Casino Ltd (‘HCL’) in its business at the iconic Hippodrome premises on Leicester Square, London.
• HMRC v Hotel La Tour Ltd [2024] EWCA Civ 564: Isabel McArdle appeared for the successful Appellants in the appeal concerning whether use of services such as market research, buyer shortlisting, financial modelling and tax compliance in an exempt sale of shares prevented recovery of input tax arising, or whether such input tax was recoverable as attributable to the downstream taxable business of the Respondent, because the ultimate aim of the share sale was to raise funds for the taxable downstream activity.
• Barclays Service Corporation v. HMRC [2024] UKFTT 785 (TC): Edward Waldegrave successfully appeared in the First-tier Tribunal in this case concerning VAT grouping.
• CCLA Investment Management v HMRC [2024] UKFTT 636 (TC): Matthew Donmall appeared in a VAT appeal concerning output tax of over £70m on services for charity investment funds (successfully in respect of 6 funds, partially successful in respect of 7 funds).
• Carey Group PLC v Ricketts (VO) [2024] UKUT 356 (LC) (15 November 2024): Matthew Donmall appeared successfully in a rating appeal concerning London offices rendered unoccupiable due to water ingress through a kicker joint.
• HMRC v Gray & Farrar International LLP [2023] EWCA Civ 121: Sarabjit Singh KC 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.
• Build-a-Bear UK Holdings Ltd v HMRC [2022] EWCA Civ 825: Owain Thomas KC and Paul Reynolds in customs duty case on imports of toy accessories.
• Mainpay Ltd v HMRC [2022]: Sarabjit Singh KC was instructed as lead counsel in an appeal before Court of Appeal on whether a supply is of exempt medical care (Upper Tribunal decision at [2021] UKUT 270 (TCC)).
• Kaplan International Colleges (UK) Ltd v HMRC: Owain Thomas KC was instructed in a VAT exemption case. This case is perhaps the last reference to the CJEU from a domestic court before Brexit.
• R (oao Gloucestershire Hospitals NHS Foundation Trust) v HMRC [2023] UKUT 00028: Owain Thomas KC appeared for the Trust in a judicial review of HMRC’s decision to deny COS recovery.
• Ampleaward Ltd v HMRC [2021] EWCA Civ 1459: Natasha Barnes led Paul Reynolds in a Court of Appeal case concerning the lawfulness of the ‘fall back’ provisions relating to acquisition tax due on cross-border supplies.

Members of the tax and rating team act for both taxpayers and HMRC in cases involving VAT, customs and excise duties, landfill tax and direct tax, and for ratepayers and the VOA in rating and valuation cases. Members have also spoken, written about and advised on emerging issues concerning the taxation of cryptoassets.

Chambers is unusual in that it has particular expertise in both litigation in the tribunals and appellate courts, as well as a forensic specialism in all aspects of judicial review. As one of the leading sets in public and administrative law, our tax and rating expertise is therefore combined with a unique and complimentary public law parallel. Members of 1COR’s tax and rating team are regularly instructed by both claimants and HMRC in judicial review challenges involving matters such as accelerated payment notices, questions of jurisdiction, enforcement and territoriality, as well as broader based public law challenges involving discrete aspects of tax administration.

We accept instructions from solicitors, accountants, surveyors, companies, crypto firms and individual taxpayers alike, and a number of our team are qualified to act on a direct access basis.

Our team is highly regarded by legal directories; “A brilliant set. All the barristers are such good quality and so clever. The silks are first class and the juniors are excellent.”- Legal 500 

“1 Crown Office Row has a broad bench of practitioners able to assist clients with the full range of indirect tax law issues. They are well respected for their advocacy skills and appear in cases across all levels of the UK court system.” “The clerks at 1COR are efficient and reliable, and always such a pleasure to deal with.” – Chambers & Partners

“This set is filled with excellent barristers who are at the top of their game. The silks are of an impressive calibre and the juniors are hugely impressive.”  – Legal 500