Northgate Tax Chambers is the Chambers of Charlotte Brown, a sole practitioner at the Bar.
Charlotte advises and represents clients across all direct and indirect taxes, with particular expertise in VAT, Customs and Excise Duty. Having previously worked within the tax litigation team of a solicitors’ firm, and more recently within the indirect tax dispute resolution team of a Big 4 accountancy firm, Charlotte has significant experience in handling disputes between taxpayers and HMRC, and in complying with the practice and procedure of the tax tribunals.
She has acted for both national and international clients, including individuals, small and medium enterprises and blue chip companies.
Charlotte works with clients and their professional advisers, providing advice, litigation support and representation at the tax tribunals and higher courts. She is able to assist on technical issues as well as procedural issues, such as objections to stays, disclosure applications and costs claims.
Charlotte was appointed to the Attorney General’s Regional C Panel in 2018.
Charlotte won the Taxation’s Rising Star award at the Tolley’s Taxation Awards 2018. This highly prestigious award is given to an individual who, while not yet at the height of their career, is rapidly making a name for themselves in the tax world.
1. Indirect TaxesExpand
Charlotte advises and represents both taxpayers and HMRC on the full range of indirect taxes, with significant experience in VAT, Customs and Excise Duty issues.
- HMRC v Cheshire Centre for Independent Living  UKUT 0275. Successful costs application against HMRC for unreasonable behaviour where HMRC was the successful party.
- The Ice Rink Company Ltd & Anor v HMRC  UKFTT 0350 (TC). VAT appeal remitted from the Upper Tribunal regarding the characterisation of a package supply of the hire of children’s ice skates and rink admission, considering the importance of options when supplying a package. Reported in The Sunday Times Money Section. Represented the taxpayer in the original First-tier Tribunal appeal ( UKFTT 698 (TC)) and the Upper Tribunal appeal ( STC 1026).
- Michael Coyle t/a Coyle Transport v The Commissioners for HM Revenue and Customs  UKUT 0113 (TCC). Out of time excise duty appeals considering the validity of assessments. Represented HMRC in the Upper and First-tier Tribunals ( UKFTT 60 (TC)).
- 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.
- Revenue and Customs Commissioners v Logfret (UK) Ltd  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 ( UKFTT 484 (TC)).
- Dodadine (trading as toucanbox) v Revenue and Customs Commissioners  UKFTT 748 (TC). VAT characterisation of supply of children’s subscription boxes containing magazines and craft activities.
- Hussain v Revenue and Customs Commissioners  UKFTT 529 (TC). Appeal against Personal Liability Notice relating to inaccuracies in VAT returns.
- Glover and another v Revenue and Customs Commissioners  UKFTT 426 (TC). Out of time applications against excise duty assessments.
- Cheshire Centre for Independent Living v Revenue and Customs Commissioners  UKFTT 354 (TC). VAT treatment of Payroll Services for recipients of Direct Payments, whether the Welfare Exemption was applicable or not.
- Ad Hoc Property Management Ltd v Revenue and Customs Commissioners  UKFTT 315 (TC). Costs application relating to a VAT appeal regarding the VAT treatment of Property Guardians.
- Coyle (trading as Coyle Transport) v Revenue and Customs Commissioners  UKFTT 60 (TC). Out of time excise duty appeals and the validity of assessments. Upper Tribunal decision pending (represented HMRC in the Upper and First-tier Tribunals).
- Pegasus (Manchester) Limited v HMRC  UKFTT 0126 (TC). VAT treatment of supplies of takeaway food.
- Fresh Catch Limited v Her Majesty’s Revenue and Customs  UKFTT 0196 (TC). Customs Duty Civil Evasion penalty.
- 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.
- Substantia Invest Limited v The Commissioners for Her Majesty’s Revenue and Customs  UKFTT 0671 (TC). VAT appeal against refusal to allow input VAT tax claims predominantly relating to legal fees.
2. Direct TaxesExpand
Charlotte advises businesses and individuals, covering corporate, personal and capital taxes, including those with an international element. Recent examples of Charlotte’s direct tax work include:
- Advising on the merits of an appeal relating to the tax treatment of loans from an offshore company to a UK-resident non-domiciled individual. This involved consideration of whether the payments represented remuneration, as well as the beneficial loan and transfer of overseas assets provisions.
- Advising a family in relation to Inheritance Tax planning involving the family home, looking specifically at the pre-owned asset and gifts with reservation of benefit rules.
- Representing a taxpayer in the restaurant industry in its appeal against assessments relating to Self-Assessment Income Tax, PAYE, NICs and associated penalties and interest. Following settlement negotiations with HMRC, the taxpayer’s liability was reduced to a third of the original assessments without recourse to the Tribunal.
- 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.
- Advising a taxpayer regarding an unauthorised payment charge, surcharge and scheme sanction charge relating to sums that had been paid out of a company pension scheme. This involved a consideration of the law relating to genuine error and mistake.
- Advising a taxpayer in relation to the correct tax treatment of a multi-million pound commission payment and associated penalties for deliberate behaviour. Involving issues of corporation and income tax, mitigation of penalties, a procedural application to amend the grounds of appeal and a successful application to HMRC’s ADR process.
- Representing a taxpayer in a Judicial Review application relating to HMRC’s COP 9 Procedure.
- Assisting taxpayers in relation to procedural and technical challenges to enquiries, discovery assessments, HMRC investigations, information requests and the imposition of penalties.
- Advising taxpayers on their tax position under the statutory residence test.
- Advising taxpayers in relation to the application and scope of Entrepreneurs’ Relief.
- Advising and representing taxpayers in relation to Personal Liability Notice appeals.
- Advising and representing taxpayers in relation to long-running enquiries into Gift Aid Claims for gifts of AIM-listed shares to charities.
3. Education & QualificationsExpand
- Chartered Institute of Taxation Advanced Diploma in International Taxation (2008)
- LLM (Tax) King’s College, University of London (2008)
- LLB King’s College, University of London (2005)
- Wakefield Girls’ High School (1994-2001)
4. Professional MembershipsExpand
- VAT Practitioners’ Group
- Customs Practitioners’ Group
- Revenue Bar Association
5. Publications and SeminarsExpand
Charlotte has written articles for professional publications and presented to professional and lay clients at a number of seminars.
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. Please contact Chambers to discuss further.
Details of Charlotte’s upcoming seminars and how to book may be found here.