Rebecca Murray

Rebecca Murray has a tax litigation and advisory practice, specialising in private client, corporate tax, VAT, SDLT and judicial review, advising and representing all sizes of corporates and individuals, as well as acting for HMRC on the full range of direct and indirect tax issues.

Reported cases include: Beresford v HMRC [2024] UKFTT 952 (business property relief on office rental); Brindleyplace v HMRC [2024] UKFTT 808 (SDLT on acquisition of a property complex using a JPUT); AD Bly v HMRC [2024] UKUT 104 (whether a provision in the accounts was wholly and exclusively for the purposes of the trade); Benoit D’Angelin v HMRC [2024] UKFTT 462 (business investment relief for remittances); Bell & Ors v Revenue & Customs [2023] UKFTT 989 (for HMRC, tax relief claimed for shares gifted to charity); Mypay [2023] (umbrella company, temporary workplace travel expenses); NWM [2023] (travel and subsistence); Nourish [2023] EWHC (interim relief by way of restoration of VAT registration); AML Tax (UK) Limited (DOTAS) [2022]; A D BLY [2021] (expense in accounts not wholly and exclusively for the purposes of the trade); Ball Europe [2021] (discovery assessments); Smartpay (DOTAS) [2022] UKFTT; White-Collar Financial [2020] UKFTT (DOTAS); Wilson (UT, question whether a member of an LLP was an employee); Sippchoice [2020] UKUT (payment of shares in discharge of a debt obligation a “contribution paid” to a SIPP); Sippchoice [2017] UKUT 87 (whether pension provider acted reasonably); as well as Atholl House [2019] UKFTT (IR35, whether Kaye Adams was, hypothetically, employed by the BBC).

Ms Murray brings broad in-depth experience of all areas of tax to her advisory practice. She recently acted as sole tax counsel in several UHNW planning and divorce matters, including navigating the “new residents” regime, restructuring, acting as parties’ joint expert to the family court, advising on maximising available reliefs and avoiding traps in the course of the separation of UK and overseas assets, main residences and investments, as well as interests in differing types of trusts (EBTs, disabled persons trusts and PFSI structures, including advice on transfers of assets abroad). She also recently advised on the sale and restructure of large businesses and corporate structures, including for private reasons (such as IHT and CGT relief maximisation) and restructuring for IPO purposes – particularly on transactions in securities and employment-related securities and Part 7A. She is well versed on private equity structures and has further experience in offshore discovery matters, as well as HMRC investigations.

Ms Murray also has a varied indirect tax practice, has advised on a range of VAT issues – and has appeared in a number of reported cases.