


UK TAX & COMMERCIAL RELATED DISPUTE BARRISTER
Julian Hickey is a highly experienced London Tax Barrister, specialising in HMRC tax enquiries, tax appeals, tax advice and related commercial disputes.

TAX DISPUTE RESOLUTION
Are you or your clients facing an HMRC tax investigation? Do you need support to defend your case?
With over 20 years of expertise, Julian Hickey advises corporations and private individuals on tax-related transactions, tax investigations and tax disputes with HMRC. Julian is highly experienced in representing clients in HMRC investigations and tribunals, as well as robustly defending, negotiating and managing appeals to achieve the best possible result. He has a proven track record of representing clients in high value and complex tax cases and is known for his discretion, practical thinking and approachable style.
Julian offers maximum flexibility and can advise or attend any conference / Court or Tribunal hearing virtually or where appropriate in-person throughout the United Kingdom.
RECENT NOTABLE cases
Newcastle United Football Club Limited v HMRC [2024] UKFTT 223 (16 October 2023) https://www.bailii.org/cgi-bin/format.cgi?doc=/uk/cases/UKFTT/TC/2023/TC09105.html&query=(%22.2024.)+AND+(UKFTT)+AND+(223%22)
This case concerned an application by HMRC for specific disclosure of documents. The Appellant sought the return of documents seized during a criminal investigation under section 59 Criminal Justice and Police Act 2001(‘CJPA’) but HMRC wished to retain copies for use in civil VAT proceedings. The specific disclosure application concerned several thousand documents. The Tribunal directed disclosure on the basis that the matter involved a high-value complex case where a wider disclosure than that required by rule 27 of the Tribunal Rules was appropriate; further the Tribunal was satisfied that HMRC would suffer an unfair disadvantage in the litigation as a result of lack of access to the material. Julian represented HMRC.
HMRC v IPS Progression Ltd [2024] UKFTT 136 (12 February 2024) https://www.bailii.org/cgi-bin/format.cgi?doc=/uk/cases/UKFTT/TC/2024/TC09071.html&query=(IPS)+AND+(Progression)+AND+(Limited)
This case concerned the scope of the Disclosure of Tax Avoidance Schemes (DOTAS) rules in respect of an application by HMRC for determination by the Tribunal of a penalty for failure to provide HMRC with prescribed information relating to notifiable arrangements (FA 2004, s 308(3), TMA ss 98C, 100C). The issues were whether there were notifiable arrangements, whether the Respondent was a “promoter” in relation to notifiable arrangements, whether the Respondent had a reasonable excuse and the quantum of the penalty. The penalty was less than that sought by HMRC, and the FTT accepted that a protective disclosure was not an admission that arrangements were subject to DOTAS. Julian represented IPS.
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Julian has acted for clients in two recent cases that were live streamed and are available to now view on the Court of Appeal YouTube archive:
Oisin Fanning (1 March 2023) (Court 70):
Link here: https://www.judiciary.uk/live-hearings/fanning-appellant-v-hm-revenue-customs-respondent/
Julian represented the Appellant on HMRC’s challenge to tax planning. The case involved difficult issues of statutory interpretation. The case was before Lord Justice Jackson, Lord Justice Lewis, Lady Justice Falk. This case was reported in the Times and major tax and non-tax law reports.
Paul Bell & Mark Mitchell v HMRC (25 January 2023) (Court 63):
Link here: https://www.judiciary.uk/live-hearings/bell-appellant-v-hm-revenue-customs-anr-respondents/
Julian represented Mr. Mitchell (having successfully represented the client in the First tier Tax Tribunal and Upper Tribunal) concerning the disclosure of confidential documents, and the extent to which documents can be relied on by HMRC / another party in a tax appeal. The case was before Lord Justice Arnold, Lady Justice Carr and Lady Justice Whipple. This case was reported in the Times and major tax and non-tax law reports.
Do you need to challenge a HMRC tax penalty or fine? Are you or your clients looking for representation at a First-tier Tax Tribunal, Appeal to the Upper Tribunal or Court of Appeal? As a leading tax barrister, Julian can assist. more >
DIRECT ACCESS TAX BARRISTER
Julian Hickey can be instructed directly by individuals and professionals under the Bar Direct Access scheme, which allows him, in appropriate cases, to work without a solicitor or accountant. This can save on costs and enable you to engage directly with a barrister with the specialist tax expertise you need. more >





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