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Elizabeth Wilson KC

"Thorough and meticulous, Elizabeth is good at finding solutions to complex matters."

Chambers & Partners
  • Call: 1995
  • Silk: 2021

Overview

Elizabeth Wilson practises in all areas of revenue law with particular emphasis on personal and corporate tax. Recent advisory work includes advice and planning on capital gains and income tax for individuals and trusts (onshore and offshore), inheritance tax agricultural and business property reliefs, pensions, corporate tax (loan relationships, intangibles etc), and SDLT (including the scope of s75A and other anti-avoidance measures). She advises taxpayers and the Crown.

Elizabeth’s litigation practice covers corporation tax, personal tax and SDLT and she has achieved successful outcomes for her clients in all courts from the First-tier Tribunal to the Supreme Court, both acting alone, and as the leader of a team. She is highly experienced in preparing a successful case for litigation and has a practical insight into litigating against the Revenue, having acted for the Revenue while a member of the Attorney General’s A and B Panel Counsel.

Elizabeth is regularly instructed in high-value leading cases on the corporation tax ‘unallowable purpose’ rule for loan relationships, the SDLT anti-avoidance rules, and the availability of capital allowances to offshore windfarms.

In addition to the above, she also has experience in gaming duty and remote gaming duty, petroleum revenue tax, and tonnage tax.

Elizabeth is co-editor of the International Trust and Estate Law Reports.

A copy of Elizabeth Wilson's privacy notice can be found here.

SDLT reliefs and exemptions

Fanning, Redmount, Newton-Young, M& M Builders, David Hannah

Her SDLT cases concern the key provisions for subsales, options, annuities and contingent consideration, and the charge on incorporation. Her cases are also important in the developing law on s 75A FA 2003 (the anti-avoidance rule). Some are lead cases in large scale marketed avoidance schemes. The David Hannah case is notable for its treatment of SDLT penalties for deliberate behaviour. Elizabeth has also advised on a number of SDLT cases including on leases settled out of court. Fanning is to be heard by the Court of Appeal in 2023.

Corporation tax loan relationships and tax planning

Kwik-Fit, JTI Acquisitions, Oxford Instruments, Travel Document Service, GDF Suez, Versteegh

These are all high value corporation tax cases with a focus on loan relationships and the  unallowable purpose rule. These cases have complex and contested facts with witness evidence including expert evidence.

Capital allowances

Orsted, Unicorn Tankships, Acamar, Lingfield Park  

Orsted is the leading case on offshore windfarms and what aspects of the preparatory studies and investigatory works might constitute qualifying expenditure. It is a fact heavy case, but it also raises a variety of technical and procedural issues relating to the scope of the relief, the income/capital divide and the making of assessments and claims to allowances. Unicorn Tankships is the case on the interaction between tonnage tax and capital allowances.  Acamar is a GAAP film scheme. Elizabeth led HMRC’s team to a successful outcome on every issue including trade, view to profit, GAAP accounting, and capital/income.

Inheritance tax, business reliefs and other personal and offshore taxes

Parry, Davies, Kavanagh, O’Rourke, Balfour 

Parry is the case on s 10 IHTA 1984 and s 3 (omission to exercise a right). Elizabeth acted for HMRC at all stages including the Supreme Court.  Davies concerned the interaction between the ‘transfer of assets abroad’ code and double tax treaty relief.  Kavanagh concerned business assets relief and also raised interesting points of company and trust law.   Elizabeth has also advised on a large number of BPR and APR cases which have settled favourably.  Balfour is the leading case on BPR and mixed businesses.

Gaming duties

Broadway Gaming, London Clubs Management, Aspinalls

These are the leading cases on how gaming duty and remote gaming duty applies to marketing initiatives such as cash backs and ‘free-plays’.

EU law and restitution and related tax issues

BAT, FII, Amalgamated Metals, Coin-a-drink, Shop Direct Group    

These cases not only raise difficult and far reaching points of EU and corporation tax law,  they also extend to the law on mistake, limitation, estoppel, and the UK tax treatment of compensation and damages.

Directory quotes

The Chambers Guide

Tax: Private Client
Ranking: New Silks

“Thorough and meticulous, she is good at finding solutions to complex matters.” “She has a forensic eye and is really pragmatic.” (2022)

“She possesses a lot of knowledge about inheritance tax, writes really well and is articulate.” “She is incredibly sharp and practical.” (2021)

“User-friendly and very approachable.” “She has a very nice, calm and controlled manner about her.” (2020)

Corporate Tax
Ranking: New Silks

“Her written work is very lucid and well expressed.” “She is very clear and does an excellent job presenting her cases.” (2022)

“She is very effective and excellent on technical points.” (2021)

“She has a very wide area of expertise and provides comprehensive advice in an easy-to-follow manner.” (2020)

The Legal 500

Tax: Corporate
Ranking: Leading Junior, Tier 2

‘Very bright and capable. She is extremely diligent and thorough. She had a fine analytical mind and writes very clearly.’ (2021)

‘She is an excellent junior counsel.’ (2020)

‘Her style of advocacy is robust but sensitive to the case environment.’ (2019)

Private Client: Personal Tax
Ranking: Leading Junior, Tier 1

‘Provides clear advice.’ (2021)

‘A very reassuring presence, bringing calm and clear advice.’ (2020)

‘A talented junior barrister who is great with clients.’ (2019)

Chambers and Partners Global

Tax: Private Client
Ranking: New Silks

Elizabeth Wilson KC is a new silk with a broad and successful private client tax practice. She is noted for her work for HMRC but also frequently represents taxpayers. Wilson has particular experience in APR and BPR cases, offshore trusts, partnerships and non-domiciliary tax planning. Elizabeth is described as “Thorough and meticulous, she is good at finding solutions to complex matters.” “She has a forensic eye and is really pragmatic.” (2022)

Chambers and Partners High Net Worth

Tax: Private Client
Ranking: Band 3

Elizabeth Wilson KC “is very reassuring,” says an instructing solicitor; “she has done a lot with the Revenue and knows how they think, which is very useful for us to work out how to get through things. She helps people take realistic views on things, and I like that.” Another solicitor says that “Elizabeth is hands-down the tax counsel I would go to. She has a real skill at being able to articulate highly technical tax terminology that not only you can understand as a tax practitioner but so can the lay client. She’s a real lateral thinker and her drafting is superb.” This interviewee also highlights Wilson’s “exceptional personable manner,” explaining that “she inspires confidence in the client in an area that I think is really tricky.” (2022)

New silk Elizabeth Wilson regularly advises on complex tax matters. One interviewee says: “Elizabeth Wilson is a top-notch barrister. She is good at finding solutions to complex matters. She is thorough and meticulous.” Another comments: “I think very highly of her. She is an enormously reassuring presence as an adviser. She has a forensic eye and is really pragmatic.” (2021)

One source notes that “she has a lot of knowledge about Inheritance Tax,” adding: “She writes really well and is quite articulate.” An instructing solicitor enthuses: “I am a great fan of hers. She doesn’t sugar-coat things; she tells you how it is.” Another source says: “She is incredibly sharp and very practical.” (2020)

 

Publications

Regular contributor of articles to specialist tax journals.

Contributor to Taxation of Loan Relationships and Derivatives (Butterworth).

Elizabeth lectures regularly on all aspects of tax planning.

Memberships

  • Chancery Bar Association.
  • Revenue Bar Association.
  • London Common Law & Commercial Bar Association.

Career & education

Career

March 2021 – KC

September 2016 – Appointed Junior Counsel to the Crown – “A” panel.

March 2011 – Appointed Junior Counsel to the Crown – “B” panel.

Called 1995, Middle Temple.

Education

Cambridge University (1990-1993)

Related judgements

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