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Grays' Inn Tax Bar Members
Imran S Afzal

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, and since 2007 he has been teaching the subject part-time at the LSE.

Since coming to Chambers (originally as a pupil) he has been involved in a range of domestic and international matters, acting for companies, private-clients and tax authorities. As a result he is developing a practice covering all fields of tax law (see below for examples).

In addition to advisory work Imran is happy to litigate if this will achieve the best outcome for his clients. 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.

As a general rule Imran believes that “the tax tail should not wag the dog” and therefore seeks to provide advice which is attractive from both a tax and commercial perspective. Nonetheless his desire to achieve the best tax outcome ensures that when the opportunity arises the dog comes on stage tail first.

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:

  • Taxation of offshore trusts
  • Transfer of Assets Abroad provisions: compatibility with EU law
  • Permanent establishments
  • Situs of debts
  • Partnership dissolutions
  • Partnership “residence” (place of control and management)
  • CGT: conversion of bonds
  • CGT: “unconditional contract” planning
  • CGT: taper relief
  • CGT: debt relief
  • SDLT planning
  • Stamp duty planning
  • VAT reverse charges
  • VAT on postal services
  • Compound interest on overpayments of tax
  • Domicile & preparation of “domicile packs”
  • Discovery assessments
  • NICs planning
  • Tax Deeds
  • Employment income tax
  • Business income tax
  • Apportionment of consideration and expenditure
  • Vodafone Group Plc's Indian tax dispute
  • Taxation of domestic and foreign dividends: compatibility with EU law
  • VAT on barter transactions / valuation of non-monetary consideration

 

CASES

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

 

PUBLICATIONS

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)

BA 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