"She is brilliant. She has a really impressive ability to identify the key legal and factual elements of a case and put forward incredibly concise arguments."

Chambers UK

Rebecca Murray

Year of Call: 2001

"She is brilliant. She has a really impressive ability to identify the key legal and factual elements of a case and put forward incredibly concise arguments."

Chambers UK

Rebecca Murray

Year of Call: 2001

"She is brilliant. She has a really impressive ability to identify the key legal and factual elements of a case and put forward incredibly concise arguments."

Chambers UK

Rebecca Murray

Year of Call: 2001

Rebecca Murray

"She is brilliant. She has a really impressive ability to identify the key legal and factual elements of a case and put forward incredibly concise arguments."

Chambers UK

Rebecca Murray

Year of Call: 2001

Rebecca Murray has a tax litigation and advisory practice in private client and corporate tax and VAT, as well as substantial experience of judicial review.

She has appeared in courts and tribunals at all levels on a range of direct and indirect tax issues. 

Her tax expertise is recognised in the directories, where she is described as "A pleasure to deal with. She quickly grasps the issues and deals with them very effectively and efficiently." and "Diligent and very bright."

Her textbook “Tax Avoidance” (Sweet & Maxwell, 4th edition March 2020) has been described as “brilliant” and as providing “comprehensive coverage of some extremely difficult areas of the law”

Before commencing independent practice, she was a chartered tax adviser in a large accountancy firm, where she advised clients on complex tax transactions involving all areas of direct tax in private client and owner managed businesses. She then worked at JP Morgan Chase advising on transactions including bank acquisitions, corporate tax, income tax, capital gains tax and VAT.

Rebecca Murray is a member of the Attorney General’s 'C' Panel of Civil Counsel to the Crown.

  • Recommendations

    Active on the Attorney General's panel, she has a growing reputation at the Tax Bar for handling private client work, as well as cases concerning corporate tax and IR35 issues. Her practice includes both advisory and litigation matters. Murray counts a number of FTSE 100 companies among her clients. "Bright and hard-working." "Very user-friendly, she takes a commercial approach and is calm under pressure." Acted in Atholl House Productions v HMRC, a case concerning whether television presenter Kaye Adams was subject to additional income taxation based on her IR35 status. - Tax, Chambers UK Bar 2021

    A former chartered tax adviser in a large accountancy firm and also an alumnus of JPMorgan Chase, she has a wealth of experience of advising on private client tax matters. Murray has published a well-received textbook entitled 'Tax Avoidance'.  "Intelligent, industrious, clear and concise. She has a superb grasp of the law." - Tax: Private Client, Chambers UK Bar 2021

    ‘Very clear in her advice and very easy to work with.’ - Tax: Corporate, Legal 500 2021

    ‘An outstanding junior.’ - Private Client: Personal Tax, Legal 500 2021

    "She is an outstanding junior as she is highly intelligent, grasps the law well and is clear and concise in her advice." Appeared in the Court of Appeal in Arthur v HMRC. - Tax, Chambers UK Bar 2020

     'She has a very keen mind, is incredibly hard-working and driven.’ - Tax: VAT, Legal 500 2020

    'She is a real star in contentious matters' - Tax: Corporate, Legal 500 2020

    "A pleasure to deal with. She quickly grasps the issues and deals with them very effectively and efficiently." "Diligent and very bright."  Tax, Chambers UK Bar 2019

    Well prepared and fights her corner in court.Tax, Legal 500 2019

    "She is brilliant. She has a really impressive ability to identify the key legal and factual elements of a case and put forward incredibly concise arguments." "A pleasure to work with." - Tax, Chambers UK 2018

    ‘A rapidly rising star at the tax Bar.’ ‘Excellent technical tax expertise tempered with a sense of realism.’ - Tax, Legal 500 2018

  • Tax

    Add to Portfolio

    Rebecca has experience of all aspects of private client, corporate tax and VAT work, as well as substantial experience of judicial review.

    She has appeared at all levels of courts and tribunals from the First Tier Tribunal (Tax) to the Supreme Court, on a range of direct and indirect tax issues.

    She has been instructed on two of the largest tax avoidance cases of recent years, Eclipse Film Partners (No 35) LLP v HMRC [2015] EWCA Civ 95, led by Malcolm Gammie QC, and Tower MCashback led by Kevin Prosser QC, concerning tax avoidance schemes involving over £4billion of tax.

    She appeared in BAA v HMRC in the Court of Appeal, led by Roderick Cordara QC and David Southern QC, on a European law point relating to the recovery of input tax incurred by a takeover vehicle.

    She was also instructed on the early judicial reviews of accelerated payment notices. R (Rowe) v HM Revenue & Customs [2015] EWHC 2293 (Admin) and R (Walapu) v HM Revenue & Customs [2016] EWHC 658 (Admin).

    Recent cases include:

     

    Supreme Court

    • Eclipse Film Partners v HMRC (April 2016): Junior Counsel for the Crown led by Malcolm Gammie QC (Eclipse was refused permission at oral hearing)
    • Commissioners for HM Revenue & Customs v Tower MCashback LLP 2 [2011] UKSC 19: Junior Counsel for the Crown, led by Kevin Prosser QC

     

    Court of Appeal

    • Arthur v HMRC [2017] EWCA Civ 761
    • Donaldson v HMRC [2016] EWCA Civ 761
    • Donaldson v HMRC (OPH) [reference]
    • BAA v HMRC [2013] EWCA Civ 112
    • HMRC v Donaldson [2014] UKUT 0536 (TCC): Appointed sole advocate to the Upper Tribunal by the President of the Upper Tribunal

     

    High Court (Queen’s Bench Division, Administrative Court)

    • R (Walapu) v HM Revenue & Customs [2016] EWHC 658 (Admin)
    • R (Rowe) v HM Revenue & Customs [2015] EWHC 2293 (Admin)

     

    Upper Tribunal

    • HMRC v Sippchoice Ltd [2020] UKUT 149
    • HMRC v Shaw & Rogers [2019] UKUT 406 (TCC), [2020] 4 WLR 23
    • HMRC v Goldsmith [2019] STC 2512
    • HMRC v Sippchoice [2017] UKUT 87
    • Hills & Anor v Revenue And Customs [2016] UKUT 189

     

    First-tier Tribunal (Tax Chamber)

    • Wilson v HMRC [2020] UKFTT
    • NT ADA LIMITED v Revenue & Customs [2019] UKFTT 333 (TC)
    • Atholl House Productions Limited v Revenue & Customs [2019] UKFTT 0242 (TC)
    • Lorimer v Revenue and Customs (PROCEDURE : Other) [2016] UKFTT 315
    • Hasbro European Trading BV v HMRC [2015] UKFTT 186

     

    Advisory and Tax Planning

    Rebecca practises in all areas of direct tax and VAT

    • Tax avoidance litigation
    • Employment related taxation
    • Capital gains tax (and corporation tax on chargeable gains)
    • Property transactions
    • Private equity transactions
    • IHT planning, pensions and QROPS
    • Insolvency and administration
    • Bankruptcy litigation
    • Tax planning (residence and domicile)
    • All aspects of VAT
    • SDLT
  • Off-payroll working (IR35)

    Add to Portfolio

    Rebecca Murray has acted for individuals receiving income via personal service companies, for HMRC against agency/umbrella companies, and for partners of partnerships and LLPs in relation to questions of "employment or self-employment"​.  

    Recent reported cases include Atholl House Productions v HMRC [2019] UKFTT 242, in which she successfully appeared as sole Counsel for Kaye Adams, BBC Presenter. 

    To view her webinar on the case law principles applied by the tribunal in recent cases please click here.

Memberships and Associations

Fellow of the Chartered Institute of Tax and representative on the corporation tax committee

Full member of the Society of Trusts and Estates Practitioners

Revenue Bar Association (RBA) Committee member and Bar Council representative

VAT Practitioners Group

Bankers Taxation Circle

Awards and Scholarships

Pro Bono Awards Highly Commended Pro Bono Junior of the Year 2018

Publications

Tax Avoidance (Sweet & Maxwell) 1st, 2nd, 3rd and 4th ed edition.

Contributor to Simons Direct Tax Service