Edward Hellier

Among other areas he has experience in:

VAT matters including: partial exemption; single and multiple supplies; and reduced rates and exemptions (such as the land exemption and the reduced rate for energy-saving materials);
IHT matters including Business Property Relief;
SDLT matters including: substantial performance and contracts providing for conveyance to a third party; and Multiple Dwellings Relief;
Business rates and council tax;
Entrepreneurs’ Relief and the Substantial Shareholding Exemption;
Corporation tax matters including those concerning Double Taxation Conventions;
Follower Notices and Accelerated Penalty Notices;
Penalties; and
Procedural matters and the application of the TMA 1970.

Ed is a member of the Revenue Bar Association, and has previously been a member of the IFS’s Tax Law Review Committee. He accepts instructions to act and advise on the full range of Chambers’ practice areas both as Junior Counsel and on his own.

Current work:

Amongst other matters, Ed is currently working on cases concerning SDLT, VAT on energy saving materials, and capital allowances. He is also involved in a project concerning the taxation of cryptocurrencies and NFTs.

Supreme Court

News Corp UK & Ireland Ltd v HMRC [2023] UKSC 7 – the application of the zero rate in VAT. Concerning broader issues of statutory interpretation, including the always speaking principle.

Court of Appeal

BlueCrest Capital Management LP and others v HMRC [2023] EWCA Civ 1481 – taxation of partnerships and miscellaneous income.
HMRC v LG Park HT1 Ltd & ors [2023] EWCA Civ 1193 – the transfer of market value to the Land Chamber in SDLT proceedings
BCM Cayman LP & Anor v HMRC [2023] EWCA Civ 1179 – taxation of partnerships and loan relationships
Greenspace (UK) Ltd v HMRC [2023] EWCA Civ 106 – the application of reduced rate VAT to building supplies.
Payne and others v HMRC [2020] EWCA Civ 889 – taxable benefits for Income Tax.

Upper Tribunal

Altrad Services Limited, and Robert Wiseman and Sons LTD v HMRC [2022] UKUT 00185 (TCC) – capital allowances on asset leasing and the application of Ramsay.
LG Park GT1 Ltd v HMRC [2022] UKUT 00178 – a procedural decision concerning the correct Tribunal in which to determine an SDLT appeal.
The Medical Defence Union Ltd v HMRC [2021] UKUT 0249 (TCC) – the application of the mutual trading principle in Corporation Tax.
HMRC v Tower Resources plc [2021] UKUT 0123 (TCC) – VAT input tax recovery by a UK holding company.

First-tier Tribunal

Collins v HMRC [2024] UKFTT 00951 (TC) – Application of R&D relief in Corporation Tax.
United Biscuits v HMRC [2023] UKFTT 864(TC) – the application of the zero rate to food.
Lyons v HMRC [2023] UKFTT 00294 (TC) – residence and CGT.
Batten v HMRC [2022] UKFTT 00199 (TC) – interaction of the statutory residence test and the common law residence test.
Dower v HMRC [2022] UKFTT 170 (TC) – the application of the multiple dwellings relief in SDLT.
Metropolitan International Schools Ltd v HMRC [2021] UKFTT 438 – an appeal against an information notice.
Imprimatur Capital Holdings v HMRC [2019] UKFTT 0736 (TC) – VAT case concerning input tax recovery by an investment fund.
Anna Cook v HMRC [2019] UKFTT 0321 (TC) – application of the private tuition exemption in VAT to dance classes.
Romima Ltd (and others) v HMRC [2019] UKFTT 0736 – VAT case concerning vouchers.

In addition Ed has been instructed:

In a case concerning VAT partial exemption. Settled before trial;
On Accelerated Payment Notice matters;
On a taxpayer Judicial Review; and
On a VAT matter concerning security for money that settled before trial.

‘‘Highly organised and very bright, he is an up and coming talent”- Chambers and Partners 2024.
‘‘Hands-on, brilliant attention to detail, responsive and very capable” – Legal 500 (2024).

2015-2016: City Law School, City University London; BPTC (Outstanding)
2014-2015: City Law School, City University London; GDL (Distinction)
2010-2013: Oxford University; BA (Hons) History (Prelims, Distinction)

Scholarships and Prizes: