Nicholas specialises in tax litigation. He was called to the Bar in 2013, after undertaking the BCL at the University of Oxford and obtaining a first-class law degree from the University of Reading. He came top of his year in various subjects at both undergraduate and postgraduate level and has won a number of academic prizes and scholarships.
Nicholas acts for both taxpayers and HMRC, as either sole or junior counsel. He has experience of acting in tribunals and courts of all levels, including the Supreme Court. He was appointed by HM Attorney General to the C Panel of Counsel in 2017 and was promoted to the B Panel in 2022. He is recommended as a leading tax junior in the Legal 500 and Chambers & Partners directories.
Prior to joining Chambers, Nicholas spent 10 years at the commercial chancery bar where, in addition to his tax practice, he assisted clients with disputes in a range of practice areas, including private client, pensions, insolvency, commercial, real estate, charities and professional negligence. In 2015 he was seconded to the Court of Appeal as a judicial assistant, where he was assigned to Lord Justice Longmore and worked on a number of important appeals in the tax, commercial and chancery fields.
Nicholas is a member of the Revenue Bar Association, Chancery Bar Association and Association of Pension Lawyers.
- LLB (Hons), 1st class (University of Reading)
- BCL (Oxford) (St Hugh’s College)
- Best performance in equity and trusts (undergraduate)
- Best performance in land law (undergraduate)
- Achievement prize for examination performance (undergraduate)
- Best performance in advanced property and trusts (postgraduate)
- Lord Denning Scholarship (Lincoln’s Inn)
- Hardwicke Entrance Award (Lincoln’s Inn)
- Buchanan Prize (Lincoln’s Inn)
- Wolfson Scholarship (Lincoln’s Inn)
Supreme Court
- Tinkler v HMRC [2021] UKSC 39 – appeal concerning whether a taxpayer was estopped by convention from denying the validity of an enquiry
Court of Appeal
- London Luton Hotel BPRA Property Fund LLP v HMRC [2023] EWCA Civ 362 – appeal concerning whether expenditure qualifies for business premises renovation allowances
- Ingenious Games LLP and ors v HMRC [2022] EWCA Civ 1015 – application under CPR r.52.30 to seek to re-open the refusal of permission to appeal
- Ingenious Games LLP and ors v HMRC [2021] EWCA Civ 1180 –appeal concerning when limited liability partnerships are carrying on a trade with a view to profit
- Higgins v HMRC [2019] EWCA Civ 1860 – appeal concerning when a taxpayer’s “period of ownership” begins in the context of principal private residence relief from CGT
High Court and Upper Tribunal
- Barklem v HMRC [2024] EWHC 651 (Ch) – proceedings concerning a failed film partnership scheme
- Pitt v HMRC [2024] UKUT 21 (TCC) – appeal in relation to a penalty issued in relation to a follower notice
- Shah v Pensions Regulator [2023] UKUT 183 (TCC) – pensions dispute concerning an individual’s liability to contribute to a pension scheme
- London Luton Hotel BPRA Property Fund LLP v HMRC [2021] UKUT 147 (TCC) – appeal concerning whether expenditure qualifies for business premises renovation allowances
- Ikeji v Bank of Scotland Plc [2021] EWHC 797 (QB) – real property dispute concerning a claim for injunctive relief in relation to a sale of property
- Ingenious Games LLP and ors v HMRC [2019] UKUT 226 (TCC) – a £1 billion appeal concerning the correct commercial and tax analysis of the activities of various LLPs involved in the film and games industries
- Pensions Regulator v Strathmore Medical Practice [2018] UKUT 104 (AAC) – appeal to the Upper Tribunal in respect of the revocation of a penalty notice issued by the Regulator
- Emblaze Mobility Solutions Ltd v HMRC [2018] UKUT 373 (TCC) – appeal in respect of an award of interest under section 84(8) of the Value Added Tax Act 1994
- Pensions Regulator v Payae Ltd and ors [2018] EWHC 36 (Ch) – dispute concerning a pensions liberation scheme
- Seven Individuals v HMRC [2017] UKUT 0132 (TCC) – appeal in relation to a joint reference made to the First-tier Tribunal in accordance with s.28ZA of the Taxes Management Act 1970 by HMRC and a number of individuals
- Bastionspark LLP and others v HMRC [2016] UKUT 0425 (TCC) – appeal concerning an award of costs made by the First-tier Tribunal (Tax) following litigation relating to amendments made to partnership tax returns
- Acornwood LLP and others v HMRC [2016] UKUT 0361 (TCC) – appeal concerning the proper tax treatment of payments made by “Icebreaker” LLPs involved in the creative industries where the amount at stake was c. £336 million
- Hill v Pensions Regulator [2016] UKUT 480 (TCC) – reference to the Upper Tribunal of a decisions of the Regulator’s determinations panel
- Ingenious Games LLP and others v HMRC [2015] UKUT 0105 (TCC) – appeal in relation to, among other things, the circumstances in which notice of allegations of dishonesty or discreditable conduct is required to be given to witnesses prior to cross-examination
First-tier Tribunal (Tax Chamber)
- Coopervision Lens Care Ltd v HMRC [2024] UKFTT 351 (TC) – application for disclosure under the tribunal rules
- The Gala Film Partners, LLP and ors v HMRC [2023] UKFTT 699 (TC) – appeal concerning a film partnership scheme
- Pitt v HMRC [2022] UKFTT 222 (TC) – income tax and loss relief – appeals concerning a scheme involving relevant discounted securities and a penalty issued in respect of a follower notice
- Acamar Productions LLP v HMRC [2022] UKFTT 74 (TC) – appeal in a multi-million pound dispute concerning the correct tax analysis of an LLP’s expenditure in connection with a major Hollywood film
- Lochurst LLP v HMRC [2021] UKFTT 231 (TC) – determination of amendments required to partnership return following the determination of the “lead case” under rule 18 of the Tribunal Rules
- Jupiter Asset Management Group Ltd v HMRC [2021] UKFTT 96 (TC) – appeal in respect of an open market value direction given under para 1 of Schedule 6 to the Value Added Tax Act 1994 in relation to supplies of management services between VAT groups
- Unistar Trading Ltd (in liquidation) and anor v HMRC [2020] UKFTT 191 (TC) – application for interest under section 84(8) of the Value Added Tax Act 1994
- London Luton Hotel BPRA Property Fund LLP v HMRC [2019] UKFTT 212 (TC) – appeal concerning whether expenditure qualifies for business premises renovation allowances
- Martin v HMRC [2017] UKFTT 0488 (TC) – procedure – contested application for a closure notice
- Ingenious Games LLP and others v HMRC [2016] UKFTT 0521 (TC) – appeal in a £1 billion dispute concerning the correct commercial and tax analysis of the activities of various LLPs involved in the film and games industries
