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Grays' Inn Tax Bar Members
Imran S Afzal

Imran read Law at Oxford as an undergraduate and postgraduate, coming top of the university on both occasions. He studied tax as part of both his BA and BCL degrees, winning prizes in all the tax exams he sat. From 2007-2013 he taught tax part-time at the LSE, and he is presently one of the tutors on the MA in Taxation at the IALS.

Since coming to Chambers (originally as a pupil) Imran has been involved in a range of domestic and international matters, acting for companies, private-clients and tax authorities. In 2012 he was appointed to the Attorney-General's C Panel. His practice covers all fields of tax law, and examples of the matters he has been involved in are listed below.

In addition to advisory work Imran is regularly involved in litigation. He has been involved in cases, both domestically and abroad, on behalf of taxpayers and revenue authorities. Indeed, he first made oral submissions, shortly after commencing practice, before the Privy Council in Mauritius.

Imran is often instructed in high-profile and high-value matters. By way of example, he has: (1) advised in relation to a multi-billion dollar settlement; (2) assisted a foreign company in a matter involving over £1 billion; (3) acted for an oil company in a foreign dispute; (4) appeared for HMRC in the Littlewoods compound interest litigation; and (5) been instructed by HMRC in relation to various partnership loss appeals (e.g. the Icebreaker litigation).

Outside of work his interests include travelling, politics, reading (in particular about business, politics, and the history of the Indian Subcontinent), and cars (he attributes his growing passion for classic cars, and any negative impact this may have on his finances, to the time he spent sitting with David Goldberg QC as a pupil).

 

AREAS OF PRACTICE

Inter alia Imran has advised or litigated on the following matters:

  • Business income tax
  • Employment income tax
  • CGT (e.g. debt relief, conversion of bonds, taper relief)
  • Compatibility with EU law of domestic legislation
  • VAT (e.g. reverse charges, barter transactions, postal services)
  • Taxation of offshore trusts
  • Partnership taxation (e.g. dissolutions, place of control and management, losses)
  • SDLT and stamp duty
  • NICs
  • Domicile & preparation of “domicile packs”
  • Compound interest on tax repayments


CASES

Emblaze Mobility Solutions Ltd v HMRC – First Tier Tribunal (Tax)

Littlewoods Retail Ltd and others v HMRC – High Court (2013)

Malcolm Healey v HMRC - First Tier Tribunal (Tax) - [2013] UKFTT 176 (TC)

Acornwood LLP & others v HMRC ("Icebreaker litigation") - First Tier Tribunal (Tax)

National Bank of Kuwait (International) plc v HMRC - First Tier Tribunal (Tax) - [2012] UKFTT 345 (TC)

Blumenthal v HMRC – First Tier Tribunal (Tax) - [2012] UKFTT 49 (TC)

Sharon Investments Ltd v Mauritius Revenue Authority - Privy Council - [2011] UKPC 34

Mark Higgins Rallying v HMRC - First Tier Tribunal (Tax) - TC/2010/1682

Littlewoods Retail Ltd and others v HMRC - High Court - [2010] EWHC 2771 (Ch)

West Midlands Strategic Health Authority v HMRC - First Tier Tribunal (Tax)

Littlewoods Retail Ltd and others v HMRC - High Court - [2010] EWHC 1071 (Ch)

Mirbel and others v the State of Mauritius and others - Privy Council - [2010] UKPC 16

Hurnam v Bhoolah and Boolah - The State of Mauritius intervening - Privy Council - [2010] UKPC 12


RECOMMENDATIONS

Legal 500, Tax: corporate and VAT (2012)

  • “One of the best young juniors at the tax Bar“

Chambers & Partners, Tax: Private Client (2013)

  • Imran Afzal is listed as an up-and-comer this year, after impressing in a series of high-profile cases: "He is extremely impressive, and a very clever man. He deals with things swiftly and to a high level. Afzal is wise beyond his years."
  • Ranked as “Up and Coming”

Chambers & Partners, Tax: Private Client (2014)

  • Focuses on private client representation as part of a broad corporate and personal tax practice. He handles both advisory work and dispute resolution.

  • Ranked as “Up and Coming”


PUBLICATIONS

Case Note: Mark Higgins Rallying v HMRC - Partnership Residence - GITC Review, Vol XI, No.1

Case Note: Pitt v Holt; Futter v Futter - The Rule in Hastings-Bass & Mistake  - GITC Review, Vol XI, No. 1

Domicile: Basic Principles, Common Misconceptions and Preparing for the Future - GITC Review, Vol IX, No. 3

Thoughts On Drummond & The Judicial Approach To Anti-Avoidance - GITC Review, Vol IX, No. 1

Case Note: Drummond v CCR - 2010 BTR 25

Flip-Flop Schemes & Burton - GITC Review, Vol IX, No. 2


EDUCATION


MERTON COLLEGE, OXFORD UNIVERSITY (2003-2007)

MA Jurisprudence: First (Class Rank: 1st in the university)

  • Only student with first class marks in all nine Finals papers
  • Martin Wronker Prize for best performance in Finals in the university
  • Top Gibbs Prize for best overall performance in Contract, Tort, Trusts and Land Law in Finals
  • 3 Verulam Buildings Prize for best performance in Commercial Law in Finals
  • McGrigors Prize for best performance in Taxation Law in Finals
  • Norton Rose Prize for best performance in College in Law Mods
  • Various College Prizes

BCL: Distinction (Class Rank: 1st in the university)

  • Awarded a scholarship by the Arts & Humanities Research Council
  • Highest marks in all four papers (all first class)
  • Vinerian Scholarship for best performance in the university
  • Gray’s Inn Tax Chambers Prize for best performance in Personal Taxation
  • KPMG Prize for best performance in Corporate & Business Taxation
  • Allen & Overy Prize for best performance in Corporate Insolvency Law
  • Book Prize from Merton College


BPP LAW SCHOOL, LONDON (2007-2008)

Bar Vocational Course: Outstanding (Class Rank: 9th)

  • Awarded Mansfield Scholarship, Hardwicke Scholarship, Buchanan Prize and Megarry Scholarship (for pupillage) by Lincoln’s Inn