Profile

Supreme Court

Eclipse Film Partners v HMRC (April 2016) Junior Counsel for HMRC led by Malcolm Gammie QC (Eclipse was refused permission at oral hearing).

Commissioners for HM Revenue & Customs v Tower MCashback LLP 2 [2011] UKSC 19: Junior Counsel for HMRC, led by Kevin Prosser QC.

 

Court of Appeal

Arthur v HMRC [2017] EWCA Civ 761 Sole Counsel for the taxpayer (acting pro bono).

R(oao Rowe) v HMRC [2017] EWCA Civ 2105.  Junior Counsel for the taxpayers led by Jessica Simor QC and David Southern QC.

Donaldson v HMRC [2016] EWCA Civ 761 (unled) penalty appeal affecting 600,000 taxpayers.

Eclipse Film Partners (No 35) LLP v HMRC [2015] EWCA Civ 95, for HMRC led by Malcolm Gammie QC.

BAA v HMRC [2013] EWCA Civ 112: Junior Counsel for the taxpayer led by Roderick Cordara QC and David Southern QC

Prince Karunaraina Samurappuli Arachchige v Commissioners for HMRC [2010] EWCA Civ 1255: Junior Counsel for Mr Arachchige led by David Southern QC.

 

Upper Tribunal

Sippchoice v HMRC [2017] UKUT 87 Sole counsel for Sippchoice in an appeal by HMRC.

Hills & Anor v Revenue And Customs [2016] UKUT (costs appeal, sole counsel for the taxpayers).

Hills & Anor v Revenue And Customs [2016] UKUT 189. Sole Counsel for the taxpayers.

Arthur v HMRC (Upper Tribunal (Administrative Appeals Chamber)) (2015) Sole Counsel for the taxpayer (acting pro bono).

HMRC v Donaldson [2014] UKUT 0536 (TCC): Appointed sole advocate to the Upper Tribunal by the President of the Upper Tribunal.

Eclipse Film Partners (No. 35) LLP v HMRC [2013] UKUT 639 (TCC) (20 December 2013): Junior Counsel for the Crown, led by Malcolm Gammie QC.

Aberdeen Asset Management Plc v HMRC [2012] UKUT 43: Junior Counsel for the taxpayer led by Kevin Prosser QC.

Commissioners for Her Majesty’s Revenue & Customs v BAA Limited [2011] UKUT 258: Junior Counsel for the taxpayer led by Roderick Cordara QC and David Southern QC.

Mr and Mrs Coll v R & C Commissioners, Upper Tribunal [2010] UKUT 114 (TCC): Junior Counsel for the taxpayer led by David Southern QC.

 

High Court (Queens Bench Administrative Division)

R (oao Walapu) v HM Revenue & Customs [2016] EWHC 658 (Admin). Junior Counsel for the taxpayer led by David Southern QC.

R (oao Rowe & Ors) v Revenue & Customs [2015] EWHC 2293 (Admin). Junior Counsel for the taxpayers led by Jessica Simor QC and David Southern QC.

 

First Tier Tribunal (Tax Chamber)

Sippchoice v HMRC [2018] UKFTT 122.  Sole counsel for the taxpayer.

Colman, Key, Schilling and Walton Partnership & Ors v Revenue and Customs (PROCEDURE: Other) [2018] UKFTT 141.  Sole Counsel for the taxpayer.

Warren v Revenue and Customs [2017] UKFTT 521.  Sole Counsel for HMRC.

MCL/DPSL v HMRC [2016] UKFTT 779.  Sole counsel for the taxpayer.

Sippchoice v HMRC [2016] UKFTT 464. Sole counsel for the taxpayer.

Hasbro European Trading BV v HMRC [2015] UKFTT 186. Sole Counsel for the taxpayer.

Tower MCashback 3 LLP v Revenue & Customs [2014] UKFTT 1081. Sole counsel for HMRC.

Moyes v Revenue & Customs [2014] UKFTT 1030. Sole counsel for the taxpayer.

Hills v Revenue & Customs [2014] UKFTT 646. Sole counsel for the taxpayer.

MCashback Software 6 LLP v Revenue & Customs [2013] UKFTT 679. Sole counsel for HMRC.

Eclipse Film Partners (No.35) LLP v HMRC [2012] UKFTT 270: Junior Counsel for HMRC, led by Malcolm Gammie QC.

Eclipse Film Partners (No.35) LLP v HMRC [2011] UKFTT 401: Junior Counsel for HMRC, led by Malcolm Gammie QC.

Aberdeen Asset Management Plc v Revenue & Customs [2010] EWCA Civ 1255: Junior Counsel for the taxpayer, led by Kevin Prosser QC.

Eclipse Film Partners (No 35 LLP) v Revenue & Customs [2010] UKFTT 448: Junior Counsel for the Crown, led by Malcolm Gammie QC.

(1) University of Essex (2) Universal Accommodation Group v C of R&C [2010] UKFTT 162: Junior Counsel for the taxpayer, led by Michael Conlon QC.

Mr John C Evans v R & C Commissioners [2010] UKFTT 140:  Sole counsel for the taxpayer.

Jigsaw Wholesale Ltd v R & C Commissioners [2010] UKFTT 164 (TC):  Sole counsel for the taxpayer.

 

OTHER LITIGATION

Rebecca has appeared in well over 100 judicial review cases on a huge range of issues, in immigration and human rights, as well as challenges to accelerated payment notices, such as Rowe and Walapu. She has acted for the Secretary of State for the Home department on the Attorney General’s C Panel, mainly in the UT. Reported cases include R (oao Chibong Lucas) v SSHD [2016] EWHC 1960.

She has also acted for the Ministry of Defence in the High Court in unreported cases, including allegations by a prisoner; human rights challenges; and a case of alleged discrimination by a district judge where the claimant was seeking damages.

She has appeared unled in the Court of Appeal, High Court (Administrative division), Upper Tribunal (Tax and Chancery Chamber), Upper Tribunal (Asylum and Immigration Chamber), Upper Tribunal (Social Entitlement Chamber), First Tier Tribunal (Tax Chamber), First Tier Tribunal (Social Entitlement Chamber) and County Court, on a vast range of direct and indirect tax issues and bankruptcy cases.

 

BOOKS

Sole author of Tax Avoidance (Sweet & Maxwell, 3rd ed. November 2016):

– UK GAAR analysis and overseas comparatives

– unique and detailed analysis of the Ramsay, sham and Abuse principles

– transfer of assets abroad

– transactions in land

– transactions in securities

– transfer of income streams

– sales of occupation provisions

– the concept of trade in a tax avoidance context

– Accelerated payment notices (“APNs”).

 

Sole Author of CCH British Tax Guide on Corporation Tax 2007-2008 (Comprehensive guide to corporation tax)

 

PROFESSIONAL MEMBERSHIPS

• CTA (2003) & Fellow of the Chartered Institute of Tax (2012) and representative on the corporation tax committee

• Member of the Society of Trusts and Estates Practitioners (2013)

• Association of Taxation Technicians (2002)

• Revenue Bar Association (“RBA”) Secretary and Committee member

• Bar Council representative

• VAT Practitioners Group