Biography

Charlotte accepts instructions from solicitors, accountants, tax advisers, businesses and individuals. She is used to working as part of a team and enjoys a collaborative approach with clients.

Whilst she is based in Manchester, Charlotte receives instructions from clients based nationwide and internationally. She is able to accept instructions from advisers on behalf of their clients, or from businesses and individuals directly under the Public Access Scheme. This means that a client does not need to go through a solicitor or accountant in order to instruct Charlotte, although she may recommend that this is done in some instances.

In addition, Charlotte is authorised to conduct litigation and work with clients throughout the litigation process, removing the administrative burdens and the pressures of litigation, ensuring proper case management, progression and adherence to deadlines. This is particularly useful for clients unfamiliar with the litigation process and for professional clients who may not have the resources to provide a tax litigation service to their client.

Tax Advisory

Illustrative examples of advisory work include:

• Advising on the availability of Capital Allowance claims.
• Advising an online peer-to-peer sales platform on the VAT implications of disclosed and undisclosed agency services.
• Advising HNWI on the various tax implications of divorce settlements.
• Advising a Diocesan Education Board on the VAT treatment of their supplies.
• Advising a tax professional’s insurance company on the merits of a negligence claim.
• Advising and representing taxpayers in relation to long-running enquiries into Gift Aid Claims for gifts of shares listed on alternative markets to charities.
• Advising taxpayers in relation to procedural and technical challenges to enquiries, discovery assessments, HMRC investigations, information requests and penalties.
• Advising taxpayers in relation to the application and scope of Entrepreneurs’ Relief.
• Advising taxpayers on estate and succession planning.
• Acting as a s.166 FSMA skilled person in a major review into potential mis-selling of interest rate hedging products by a high-street UK bank, dealing specifically with claims relating to increased tax liabilities as a result of redress payments paid to customers.

Featured Cases

• Michael Coyle t/a Coyle Transport v The Commissioners for HM Revenue and Customs [2020] UKUT 0113 (TCC). Out of time excise duty appeals considering the validity of assessments.
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•   Represented HMRC in the Upper and First-tier Tribunals ([2019] UKFTT 60 (TC)).
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• Foley v HM Revenue and Customs UT/2019/0155 (4 March 2020). Oral reconsideration application to the Upper Tribunal to admit an out of time appeal relating to excise duty.
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• Revenue and Customs Commissioners v The Ice Rink Company Ltd and another [2019] STC 1026. VAT appeal considering whether the supply of a package of admission to an ice rink and the hire of children’s skates was a composite or mixed supply. The matter has been remitted to the First-tier Tribunal. Represented the taxpayer in the Upper and First-tier Tribunals ([2017] UKFTT 698 (TC)).
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• Farrow v Revenue and Customs Commissioners [2019] UKFTT 200 (TC). Appeal against a Personal Liability Notice relating to the Construction Industry Scheme.
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• Revenue and Customs Commissioners v Logfret (UK) Ltd [2019] STC 544. Excise duty appeals dealing with novel point on the duration of duty suspended movement. Represented the taxpayer in the Upper and First-tier Tribunals ([2017] UKFTT 484 (TC)).
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• Dodadine (trading as toucanbox) v Revenue and Customs Commissioners [2019] UKFTT 748 (TC). VAT characterisation of supply of children’s subscription boxes containing magazines and craft activities.
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• Hussain v Revenue and Customs Commissioners [2019] UKFTT 529 (TC). Appeal against Personal Liability Notice relating to inaccuracies in VAT returns.
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• Glover and another v Revenue and Customs Commissioners [2019] UKFTT 426 (TC). Out of time applications against excise duty assessments.
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• Cheshire Centre for Independent Living v Revenue and Customs Commissioners [2019] UKFTT 354 (TC). VAT treatment of Payroll Services for recipients of Direct Payments; whether the Welfare Exemption was applicable or not.
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• Ad Hoc Property Management Ltd v Revenue and Customs Commissioners [2019] UKFTT 315 (TC). Costs application relating to a VAT appeal regarding the VAT treatment of Property Guardians.
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• X v Y. Judicial review application relating to legality of COP 9 investigation.
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• A v B. Closure applications for related individuals’ and company enquiries.
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• Brendan McCann v The Commissioners for Her Majesty’s Revenue and Customs [2018] UKFTT 769 (TC). Excise duty assessment and wrongdoing penalty.
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• Pegasus (Manchester) Limited v HMRC [2018] UKFTT 0126 (TC). VAT treatment of supplies of takeaway food.
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• Fresh Catch Limited v Her Majesty’s Revenue and Customs [2016] UKFTT 0196 (TC). Customs Duty Civil Evasion penalty.
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• Bellavail IMS Limited v HMRC TC/2014/05159 and TC/2016/02666. VAT treatment of supplies of highway construction services supplied in relation to new housing developments.
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• Substantia Invest Limited v The Commissioners for Her Majesty’s Revenue and Customs [2015] UKFTT 0671 (TC). VAT appeal against refusal to allow input VAT claims predominantly relating to legal fees.

Regulatory information

Charlotte Brown is a self-employed, independent barrister whose practice is governed by the Code of Conduct of the Bar of England and Wales. She is registered with The Bar Standards Board (Ref 51955) and is fully insured with the Bar Mutual Indemnity Fund (BMIF Ref 8074/013) to provide legal services; please refer to the BMIF website at www.barmutual.co.uk for full details of the world-wide cover provided.

She is registered for VAT (registration number 194 4186 81). Charlotte is also registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that she holds and processes as a barrister (registration number ZA175466).

Personal Interests

She enjoys presenting at internal seminars for firms or businesses and is happy to appear on panels or speak at conferences hosted by professional clients and practice groups. When not running around after her two young children, Charlotte enjoys playing tennis and travelling.