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 this year. 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 on the full range of indirect taxes, with significant experience in VAT, Customs and Excise Duty issues.
She was involved in the following reported cases whilst an employed barrister:
- S&I Electronics plc v HMRC  UKUT 87 (TCC) (MTIC appeal).
- Premier Telecom Solutions Limited v HMRC  UKFTT 42 (TC) (appeal against a Notice of Requirement to provide security).
- Emblaze v HMRC  EWHC B7 (challenging the legality of HMRC’s decision to set off alleged historic tax liabilities against a tax tribunal award).
- Edgeskill Limited v HMRC  UKFTT 393 (TC) (MTIC appeal).
- WM Morrison Supermarkets Plc v HMRC  UKUT 0247 (TCC) (single and multiple supplies).
- Standard Chartered Plc and anr and Lloyds Bank and anr v HMRC  UKFTT 316 (TC) (right of reimbursement under s80 VATA where VAT group disbands).
- Colaingrove Limited (verandahs) v HMRC  UKUT 0002 (TCC) (single and multiple supplies).
- HMRC v Investment Trust Companies (in liquidation)  EWCA Civ 82 (customer claims against HMRC for overcharged VAT).
- Taylor Wimpey Plc v HMRC  UKFTT 74 (TC) (‘Builders’ block’ input VAT appeal).
Recent examples of Charlotte’s indirect tax work include:
- Representing a taxpayer security business in opposing HMRC’s strike out application against a VAT appeal that was made 3 years out of time. HMRC withdrew the application following receipt of Charlotte’s skeleton argument.
- Advising an overseas company on its liability to register and account for UK VAT as a non-established taxable person in relation to supplies of goods in the UK.
- Representing a taxpayer in a postponement application, following which Charlotte represented the taxpayer in its substantive appeal against HMRC’s refusal to allow input VAT tax claims predominantly relating to legal fees: Substantia Invest Limited v The Commissioners for Her Majesty’s Revenue and Customs  UKFTT 0671 (TC).
- Representing a taxpayer business in HMRC’s application to strike out the appeal against a customs liability of over £200,000 on the basis that the incorrect decision had been appealed. HMRC withdrew the application following receipt of Charlotte’s skeleton argument.
- Representing the taxpayer in a customs duty appeal against a Civil Evasion Penalty: Fresh Catch Limited v Her Majesty’s Revenue and Customs  UKFTT 0196 (TC).
- Representing a taxpayer business in the health and fitness industry in its VAT appeal against a default surcharge on grounds of reasonable excuse and proportionality. HMRC withdrew the penalty upon receipt of the Notice of Appeal that Charlotte drafted.
- Advising a company that provides after school care and tuition as to the correct VAT treatment of its services, dealing specifically with the Welfare Exemption in Item 9(b) of Group 7 to Schedule 9 of VATA 1994.
- Advising a business on the application and scope of the VAT Insurance Exemption to its supplies of hired goods with insurance cover procured from an insurer. This also involved a consideration of single and multiple supplies, partial exemption adjustments and the application of Insurance Premium Tax.
- Representing the taxpayer in a successful appeal against excise duty assessments relating to movements that had not been receipted on EMCS: Logfret (UK) Limited v HMRC  UKFTT 484 (TC). The appeal considered novel points relating to whether a deemed irregularity (and therefore duty point) had occurred and what alternative evidence of the goods arriving at their stated destination is sufficient, as well as arguments in relation to limitation periods.
- Advising taxpayers on the customs classification, origin, valuation, preferences and reliefs across a broad spectrum of goods including medical equipment, ladies’ fashion accessories, electronic cigarettes, precious metals, automotive vehicles and construction machinery.
- Representing the taxpayer in relation to an appeal about the correct VAT treatment of supplies of highway construction services supplied in relation to new housing developments. The appeal considered the application and scope of the zero-rating provision of supplies in the course of construction of new dwellings in Note 2(a) of Group 5 of Schedule 8 of VATA: Bellavail IMS Limited v HMRC TC/2014/05159 and TC/2016/02666.
- Representing the successful taxpayer in its VAT appeal relating to single vs. multiple supplies. The appellant’s supplies of a package of skating with skate hire for children was treated as a multiple supply of standard rated entry and zero-rated hire of children’s skates: The Ice Rink Company Ltd & PI(Milton Keynes) Ltd v HMRC  UKFTT 698 (TC).
- Advising a taxpayer on the application and scope of the reduced rate for energy saving materials, including advice on the merits of a fiscal neutrality argument where competitors were applying the reduced rate to similar supplies.
- Advising and representing a taxpayer in the healthcare sector in an ADR meeting with HMRC regarding the correct apportionment methods relating to their supplies.
- Representing the taxpayer in its VAT appeal regarding the correct classification of its supplies of takeaway food: Pegasus (Manchester) Limited v HMRC  UKFTT 0126 (TC).
- Advising and representing a taxpayer in an ADR meeting relating to the Transfer of A Going Concern and Self-Supply rules in a VAT context.
- Representing a taxpayer charity in an ongoing appeal relating to the scope of the VAT Welfare Exemption in the context of Direct Payments Legislation.
- Representing a taxpayer in the property management industry in an ongoing appeal relating to the VAT treatment of supplies of land.
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.