Overview
Calypso joined Chambers as a full tenant on 7th October 2020 after completing her twelve-month pupillage. She has been recognised as a 'Rising Star' by Legal 500:
‘Calypso shows the depth and strength of her research skills in VAT disputes, as well as her ability to draft powerful and compelling submissions, boiling down a dispute to its key components. She brings a calmness and coolness to client interactions also, allowing the team to focus on the strategic aspects of the dispute.’
Calypso has a diverse tax practice and accepts instructions in all areas of Chambers’ expertise including personal tax, corporate tax, VAT, stamp taxes, customs duties and international tax. She is also qualified to accept instructions under the Public Access Scheme. Recent examples of her work are summarised in the tabs covering particular practice areas.
A copy of Calypso's privacy notice can be found here.
Private Client
Calypso has a particular interest in private client work. Recent examples of her advisory practice include:
- the scope for rectification and rescission following the creation of an immediate post-death interest under s. 49A IHTA 1994,
- assisting with an expedited application to the High Court under s. 48 AJA 1985 in relation to the exercise of the power of amendment within a trust deed,
- the deductibility of damages under s. 38 TCGA 1992 in circumstances where the award had been paid out after disposal of the asset had taken place,
- the application of the statutory residence test in Sch 45 FA 2013 to exceptional circumstances and related penalty exposure.
Corporate Tax
BlueCrest Capital Management (UK) LLP v HMRC [2023] UKUT 232 (TCC): led by Richard Vallat KC and Laura Poots for HMRC in the first case to consider the ‘Salaried Members’ legislation in ss. 863A – 863G ITTOIA 2005 which focussed on (i) the nature of the members’ remuneration and (ii) whether the members had significant influence over the affairs of the partnership.
Gala Film Partners LLP v HMRC [2023] UKFTT 699 (TC): led by Richard Vallat KC for Gala in a case concerning whether Gala’s prints and advertising business in relation to a portfolio of films was a trade carried out on a commercial basis with a view to profit. The hearing lasted 21 days before the FTT and involved 8 witnesses.
Hargreaves Property Holdings Ltd v HMRC [2023] UKUT 120 (TC): led by Richard Vallat KC for HMRC in a case concerning the duty to deduct withholding tax on interest payments made by the taxpayer company. The Tribunal considered the concepts of ‘beneficial entitlement’, ‘yearly interest’, and ‘source’, as well as the procedure for making double tax treaty claims.
Swiss Centre Ltd v HMRC [2023] UKFTT 449 (TC): led by Edward Waldegrave for HMRC in a case concerning whether payments to an Irish government agency out of the proceeds of the sale of the ‘Swiss Centre’, Leicester Square, were deductible under the loan relationships or chargeable gains rules. The case was heard in Belfast over 5 days.
Beard v HMRC [2022] UKFTT 129 (TC): led by Andrew Hitchmough KC (in the FTT) and David Milne KC (in the UT) for HMRC in a case concerning the treatment of distributions from a Jersey company to a UK resident individual. The question was whether they were ‘dividends’ or ‘dividends of a capital nature’ within the meaning of s. 402(4) ITTOIA 2005.
Indirect Tax
Dollar Financial UK Ltd v HMRC [2023] UKUT 256 (TCC): led by James Rivett KC for Dollar Financial in a case concerning a claim of £2m in overpaid VAT in the context of a retrospective VAT group membership application.
How Development 1 Ltd v HMRC [2023] UKUT 84 (TCC): led by James Henderson for HMRC in a SDLT case concerning whether woodland purchased with a large residential property formed part of the grounds of the property (therefore applying the higher rate of SDLT).
Hyman v HMRC [2022] EWCA Civ 185: led by James Henderson for HMRC in a SDLT case in which the Court of Appeal confirmed that the words of s. 116 FA 2003 were clear and unambiguous: there was no suggestion that, in order for garden or grounds to be residential property, they should be needed for the reasonable enjoyment of the dwelling.
Career
2019-2020 – Pupillage, Pump Court Tax Chambers
2017-2018 – Judicial Assistant, Court of Appeal
2017 – Called to the Bar (Lincoln’s Inn)
Education
2016-2017 – BPP Law School – BPTC (Very Competent)
2015-2016 – City University – GDL (Distinction)
2011-2015 – Keble College, University of Oxford – French BA
Scholarships and Prizes
2019 – JP Warner Scholarship (CJEU, Cabinet of AG Sharpston) and EFTA Court Scholarship (Liechtenstein Cabinet) (Lincoln’s Inn)
2016 – Short-listed, European Union Law essay prize (City University)
2016 – Lord Denning Scholarship (Lincoln’s Inn)
2016 – Excellence Award (BPP Law School)
2015 – Hardwicke Entrance Award (Lincoln’s Inn)
2015 – Lord Haldane Scholarship (Lincoln’s Inn)
2013 – Li and Fung Scholarship
2012 – Turl Street Anthology Prize (University of Oxford)
Languages
French (fluent)