Field Court Tax Chambers

IAfzal-profile-page.jpg
Really clever and very assiduous Chambers & Partners

Imran S Afzal

Tax Junior of the Year, The Legal 500 Bar Awards 2022

Call: 2008

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. In 2014 he founded Field Court Tax Chambers with three colleagues, having previously practised in another set of tax chambers.

He has a broad practice, and has been involved in a range of domestic and international matters, acting for companies, individuals and tax authorities. In addition to advisory work he is regularly involved in litigation. Indeed, he first made oral submissions, shortly after commencing practice, before the Privy Council in Mauritius. In 2012 he was appointed to the Attorney-General’s C Panel, in 2017 to the B Panel, and in 2022 to the A Panel.

Imran is often instructed in high-profile and high-value matters. By way of example, he has acted for:

  • Arron Banks in relation to whether the unavailability of tax relief for donations to UKIP constituted a breach of human rights and/or EU law;
  • Gallaher Ltd (part of the Japan Tobacco group) in relation to whether an “exit tax” on cross-border transfers of assets (for consideration in excess of £2 billion) was a breach of EU law;
  • the Mauritius Revenue Authority in a transfer pricing matter where the sums at stake exceeded $100 million; and
  • for HMRC in the Icebreaker and Ingenious cases.
In 2020 Imran was one of 36 people selected to participate in the inaugural Bar Council Leadership Programme. 

MERTON COLLEGE, OXFORD UNIVERSITY (2003-07)

MA Jurisprudence (2003-06): 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 (2006-07): 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 (2007-08)

Bar Vocational Course: Outstanding

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

Revenue Bar Association

Imran S Afzal’s cases include:

James Anderson and PwC v HMRC TC 2022 00110

Christian Peter Candy v HMRC [2022] EWCA Civ 1447 – Court of Appeal

Cumming-Bruce v HMRC [2022] UKUT 233 (TC) – Upper Tribunal

The Gala Film Partners LLP v HMRC – First-tier Tribunal (Tax Chamber) – decision to follow

Walewski v HMRC [2021] UKUT 133 (TC) – Upper Tribunal

Ingenious Games LLP and others v HMRC [2021] EWCA Civ 1180 – Court of Appeal

IM Group Ltd v HMRC [2021] UKFTT 82 (TC) – First-tier Tribunal (Tax Chamber)

Arron Banks v The Commissioners for Her Majesty’s Revenue and Customs [2021] EWCA Civ 1439 – Court of Appeal

Gallaher Limited v. The Commissioners for Her Majesty’s Revenue and Customs [2020] UKUT 354 (TCC) – Upper Tribunal

Irish Bank Resolution Corporation Ltd (in special liquidation) and another v HMRC [2020] EWCA Civ 1128 – Court of Appeal

Walewski v HMRC [2020] UKFTT 58 (TC) – First-tier Tribunal (Tax Chamber)

Arron Banks v HMRC [2020] UKUT 0101 (TCC) – Upper Tribunal

Avago Technologies Trading Ltd v Director General, Mauritius Revenue Authority – Assessment Review Committee, Mauritius – decision to follow

The Medical Defence Union Ltd v HMRC [2020] UKFTT 227 (TC) – First-tier Tribunal (Tax Chamber)

Gallaher Ltd v HMRC [2019] UKFTT 207 (TC) – First-tier Tribunal (Tax Chamber)

Ingenious Games LLP and others v HMRC [2019] UKUT 226 (TCC) – Upper Tribunal

McCabe v HMRC [2019] UKFTT 317 (TC) – First-tier Tribunal (Tax Chamber)

Grint v HMRC [2019] UKUT 28 (TCC) – Upper Tribunal

Mackay v HMRC [2018] UKUT 378 (TCC) – Upper Tribunal (Tax Chamber)

Irish Bank Resolution Corporation Ltd (in special liquidation) and another v HMRC [2019] UKUT 0277 (TCC) – Upper Tribunal

Arron Banks v HMRC [2018] UKFTT 617 (TC) – First-tier Tribunal (Tax Chamber)

Rajesh Gill v HMRC [2018] UKFTT 245 (TC) – First-tier Tribunal (Tax Chamber)

Littlewoods Ltd and others v Revenue and Customs Commissioners [2017] UKSC 70 – Supreme Court

Rajesh Gill v HMRC [2017] UKFTT 0597 (TC) – First-tier Tribunal (Tax Chamber)

Clavis Liberty Fund 1 LP (acting through Cowen) v HMRC [2017] UKUT 0418 (TCC) – Upper Tribunal

Seven Individuals v HMRC (Icebreaker litigation) [2017] UKUT 0132 (TCC) – Upper Tribunal

Irish Bank Resolution Corporation Ltd (in special liquidation) and another v HMRC [2017] UKFTT 0702 (TC) – First-tier Tribunal (Tax Chamber)

Grove Park Development Ltd v Mauritius Revenue Authority and another [2017] UKPC 4 – Privy Council

HMRC v Root2Tax Limited and another [2017] UKFTT 0696 (TC) – First-tier Tribunal (Tax Chamber)

Anthony Mackay v HMRC [2017] UKFTT 0441 (TC) – First-tier Tribunal (Tax Chamber)

Ingenious Games LLP and others v HMRC [2017] UKFTT 0429 (TC) – First-tier Tribunal (Tax Chamber)

Ingenious Games LLP and others v HMRC [2016] UKFTT 0521 (TC) – First-tier Tribunal (Tax Chamber)

Rupert Grint v HMRC [2016] UKFTT 0537 (TC) – First-tier Tribunal (Tax Chamber)

Shophold (Mauritius) Ltd v The Assessment Review Committee and another [2016] UKPC 12 – Privy Council

Clavis Liberty 1 LP (acting through Mr D J Cowen) TC05028 – First-tier Tribunal (Tax Chamber)

Healey v Revenue and Customs Commissioners [2015] UKUT 140 (TCC) – Upper Tribunal

Savva and others v Revenue and Customs Commissioners [2015] UKUT 141 (TCC) – Upper Tribunal

Littlewoods Ltd and others v Revenue and Customs Commissioners [2015] EWCA Civ 515 – EWCA Civ 515 – Court of Appeal

Ingenious Games LLP and others v HMRC [2015] UKUT 105 (TCC) – Upper Tribunal

Emblaze Mobility Solutions Ltd v HMRC [2014] UKFTT 0679 (TC)– First-tier Tribunal (Tax Chamber)

Littlewoods Retail Ltd & Others v HMRC [2014] EWHC 868 (Ch)– High Court

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

Acornwood LLP & Others v HMRC [2014] UKFTT 416 (TC) (“Icebreaker” litigation) – First-tier Tribunal (Tax Chamber)

National Bank of Kuwait (International) Plc v HMRC [2012] UKFTT 345 (TC – First-tier Tribunal (Tax Chamber)

Blumenthal v HMRC [2012] UKFTT 497 (TC)– First-tier Tribunal (Tax Chamber)

Sharon Investments Ltd v HMRC [2011] UKPC 34 – Privy Council

Mark Higgins Rallying v HMRC [2011] UKFTT 340 (TC) (20 May 2011)– First-tier Tribunal (Tax Chamber)

Littlewoods Retail Ltd & Others v HMRC [2010] EWHC 2771 (Ch) – High Court

Littlewoods Retail Ltd & Others v HMRC [2010] EWHC 1071 (Ch) – High Court

Mirbel & Others v The State of Maritius & Others [2010] UKPC 16 – Privy Council

Hurnam v Bholah [2010] UKPC 12 – The State of Mauritius intervening – Privy Council

Legal 500, Tax: corporate (2022)
Absolutely first-rate: extremely clever with a detailed legal knowledge. Produces top quality work every time he is involved in a matter. Will undoubtedly become a KC in the very near future.
Ranked: Band 1

Legal 500, Private Client: Personal Tax (2022)
Ranked: Band 3

Chambers & Partners UK Bar, Tax (2022)
Imran Afzal has an established reputation for his handling of a range of domestic and international tax matters including those relating to double tax treaties and transfer pricing. He represents a wide array of clients including tax authorities, companies and private clients, and acts in both contentious and non-contentious cases.
Strengths: “He is technically excellent, very insightful and a clear thinker.” “Fiercely intelligent and good on the technicalities.”
Recent work: Acted in Gallaher Limited v HMRC, a case concerning whether domestic tax relief law was in breach of EU law when transferring assets from UK companies to EU-based companies.
Ranked: Band 2

Chambers & Partners UK Bar, Tax: Private Client (2022) and Chambers & Partners Global, Private Wealth: Tax-UK (2022)
Imran Afzal is in demand from both HMRC and taxpayers for the most high-profile and complex matters, and is a particularly fine choice of counsel for tax scheme litigation and questions of residence and domicile. He is well known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue.
Strengths: “Incredibly clever, has a lot of experience and is completely on top of everything.” “He is extremely quick and has a sharp, incisive mind.”
Recent work: Instructed by the taxpayer in Nicolas Walewski v HMRC, a case concerning mixed partnership rules.
Ranked: Band 2

Chambers & Partners High Net Worth, Tax: Private Client (2022)
Imran Afzal is “a very talented junior with great attention to detail in relation to tricky points of tax law,” says a source. Another describes Afzal as “very strong technically,” and says he “drafts excellent, clear submissions.” A fellow barrister reports that “he’s brilliant and extremely good on his feet. He’s extremely bright.”
Ranked: Band 2

Chambers & Partners UK Bar, Tax (2020)
Has an established reputation for his handling of a range of domestic and international tax matters including those relating to double tax treaties and transfer pricing. He represents a wide array of clients including tax authorities, companies and private clients, and acts in both contentious and non-contentious cases.
Strengths: “Very bright and hard-working, he is able to find answers to technical questions.” “He analyses problems clearly and logically and delivers his conclusions in a comprehensible way.”
Recent work: Acted in Nicolas Walewski v HMRC, which concerned the taxation of shares under mixed partnership rules.
Ranked: Band 2

Chambers & Partners UK Bar, Tax: Private Client (2020)
In demand from both HMRC and taxpayers for the most high-profile and complex matters, Afzal is a particularly fine choice of counsel for tax scheme litigation and questions of residence and domicile. He is well known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue.
Strengths: “He is formidably bright, extremely strong academically and always prepared to roll his sleeves up. He is a very powerful written advocate.”
Recent work: Instructed for the taxpayer in Arron Banks v HMRC. The case concerned the issue of whether the absence of tax relief for donations to UKIP was a breach of human rights and a breach of European law.
Ranked: Band 2

Chambers & Partners High Net Worth, Tax: Private Client (2020)
Imran Afzal is highly rated for his tax practice. Several sources praise his intellectual ability, with one source noting: “He is formidably bright, extremely strong academically and always prepared to roll his sleeves up. He is a very powerful written advocate.” An instructing solicitor notes: “His great skill is making a difficult set of facts simple and understandable for the judge.”
Ranked: Band 2

Chambers & Partners Global, Private Wealth: Tax-UK (2020)
In demand from both HMRC and taxpayers for the most high-profile and complex matters. Afzal is a particularly fine choice of counsel for tax scheme litigation and questions of residence and domicile. He is well known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue.
Strengths: “Extremely helpful and professional, he is patient and takes time to make sure that you understand the process and the arguments. His work is detailed, well researched and extremely thorough.” “An exceptionally bright junior who is very hard-working and can be trusted to really get involved in the detail.”
Recent work: Acted for the taxpayer in Arron Banks v HMRC, a case concerning whether the absence of tax relief for donations to UKIP was a breach of human rights and/or a breach of European law.
Ranked: Band 2

Legal 500, Tax: corporate (2020)
“Very clever; can unravel the most complex of legal knots; technically excellent.”
Ranked: Band 2

Legal 500, Private Client: Personal Tax (2020)
“Very clever; can unravel the most complex of legal knots.”
Ranked: Band 3

Chambers & Partners High Net Worth, Tax: Private Client (2019)
Imran Afzal often handles avoidance scheme cases, and many of his cases involve international tax questions. An instructing solicitor says he is an “exceptionally bright junior, very hard-working, and can be trusted to really get involved in the detail. I’m sure he will have a very glittering career as a junior. He seems to be involved in a lot of interesting ongoing cases – some for the tax man but most for the taxpayer.”
Ranked: Band 2

Chambers & Partners UK Bar, Tax (2019)
Has an established reputation for his handling of a range of domestic and international tax matters including those relating to double tax treaties and transfer pricing. He represents a wide array of clients including tax authorities, companies and private clients, and acts in both contentious and non-contentious cases.
Strengths: “An exceptionally bright junior who is very hard-working and can be trusted to really get involved in the detail of a case.”
Recent work: Acted for the Revenue in Ingenious Games LLP and Others v HMRC, which related to a large film finance scheme.
Ranked: Band 2

Chambers & Partners UK Bar, Tax: Private Client (2019)
In demand from both HMRC and taxpayers for the most high-profile and complex matters, Afzal is a particularly fine choice of counsel for tax scheme litigation and questions of residence and domicile. He is well known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue.
Strengths: “Extremely helpful and professional, he is patient and takes time to make sure that you understand the process and the arguments. His work is very detailed, well researched and extremely thorough.” “An exceptionally bright junior who is very hard-working and can be trusted to really get involved in the detail.”
Recent work: Acted for the taxpayer in Arron Banks v HMRC, a case concerning whether the absence of tax relief for donations to UKIP was a breach of human rights and/or a breach of European law.
Ranked: Band 2

Chambers & Partners Global, Private Wealth: Tax-UK (2019)
Best known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue. He also has a strong taxpayer-side practice on residence and domicile matters, and on tax scheme litigation.
Strengths: “He’s excellent to work with.” “He is undoubtedly very clever.”
Recent work: Represented a taxpayer against HMRC in a case concerning whether or not particular documents constitute accounts and whether or not an accounting date was changed successfully for tax purposes.
Ranked: Band 3

Legal 500, Tax: corporate (2019)
“His intelligence and knowledge of UK tax matters is demonstrated on each engagement.”
Ranked: Band 2

Legal 500, Private Client: Personal Tax (2019)
“A clever junior of note.”
Ranked: Band 3

Chambers & Partners, Tax: Private Client (2018)
Best known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue. He also has a strong taxpayer-side practice on residence and domicile matters, and on tax scheme litigation.
Strengths: “A very, very clever man, with a razor-sharp brain. He puts the rest of us to shame; he is destined for great things. He is also extremely clear in his analysis.”
Ranked: Band 3

Chambers & Partners, Tax (2018)
Has a growing reputation for his handling of a range of domestic and international tax issues. He represents a wide array of clients including tax authorities, companies and private clients. He acts in litigation proceedings and also has a robust advisory practice.
Strengths: “He gives good, clever advice and is very detailed and thorough.” “Really clever and very assiduous.”
Ranked: Band 3

Legal 500, Tax: corporate (2017)
“Very proactive and commercial in his approach, and also a pleasure to work with.”
Ranked: Band 2

Legal 500, Private Client: Personal Tax (2017)
“Hugely knowledgeable on UK taxation and outstanding in his written work.”
Ranked: Band 3

Chambers & Partners High Net Worth, Tax: Private Client (2017)
Imran Afzal is best known among private client tax specialists for his work on the ‘Icebreaker’ partnership scheme litigation, where he acted on behalf of the Revenue. He also has a strong taxpayer-side practice on residence and domicile matters, and on tax scheme litigation. Afzal is a “very, very clever man, with a razor-sharp brain. He puts the rest of us to shame, he is destined for great things,” enthuses a source, adding: “He is also extremely clear in his analysis.”
Ranked: Band 3

Chambers & Partners, Tax: Private Client (2017)
Possesses knowledge on international and domestic tax matters. He represents high-profile clients on litigious matters, and has appeared before domestic and foreign courts.
Strengths: “He is a very bright man. He is wise beyond his years in terms of knowledge of the law, judgement and how to take particular matters forward.” “He is a very talented lawyer and very clever.”
Recent work: Represented HMRC in the Icebreaker case and on whether partnership members could claim tax relief as a result of partnership losses.
Ranked: Band 3

Chambers & Partners, Tax (2017)
Has a growing reputation for his handling of a range of domestic and international tax issues. He represents a wide array of clients in litigation and also has a robust advisory practice.
Strengths: “Incredibly thorough and really on the ball.”
Recent work: Led in a case concerning whether or not individual members of a partnership could claim tax relief in respect of disputed losses.
Ranked: Up-and-coming

Legal 500, Tax: corporate and VAT (2016)
Imran Afzal is instructed by HMRC to appear in the upcoming Supreme Court hearing of the Littlewoods VAT case.
“His work includes partnership and international cases.”
Ranked: Band 2

Legal 500, Private Client: Personal Tax (2016)
Imran Afzal successfully represented HMRC in Acornwood LLP and others v HMRC, in which the First Tier Tribunal found against the “Icebreaker” tax avoidance scheme.
“He represents taxpayers and the Revenue in a range of matters.”
Ranked: Band 3

Chambers & Partners, Tax: Private Client (2016)
Maintains a well-regarded private client practice advising both domestic and international clients. His capabilities stretch broadly across the practice area and he regularly acts in high-value and high-profile cases.
“He is very sharp, and able to consume and digest a lot of material quickly and accurately.”
“He’s very clear in his written expression and a pleasure to work with.”
Ranked: Band 3

Chambers & Partners, Tax: Private Client (2015)
A genuine tax all-rounder, with experience of acting for clients across the Tax Bar. He is comfortable handling both advisory and dispute resolution work in both the domestic and international contexts.
Expertise: “He grasps the nettle thoroughly and is able to cut through the law.”
Ranked: Band 3

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”

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”

Legal 500, Tax: corporate and VAT (2012)
“One of the best young juniors at the tax Bar”

Imran usually charges for work on a fixed fee or hourly rate basis. Occasionally Imran may charge on the basis of a daily rate (that will typically be the case if Imran is required to go abroad). Professional and licensed access clients may contact either Imran directly (ia@fieldtax.com), or one of the Practice Managers (chambers@fieldtax.com), to obtain a quotation for legal services. Additional contact details can be found on the Contact page.

If requested, Imran is happy to provide you with an indication of how long a particular piece of work is likely to take. If you have a particular deadline Imran can let you know in advance whether that is feasible. He will always endeavour to meet a client’s timescale, but his ability to do so will depend on the amount of work involved and his pre-existing commitments (in particular if he is involved in tribunal/court proceedings).

Imran wants to give you the best possible service. However, if at any point you become unhappy or concerned about the service provided to you, then you should inform us as soon as possible. Details of our complaints procedure, together with details about making complaints to the Legal Ombudsman, can be found here.

Imran is regulated by the Bar Standards Board (BSB). The Barrister’s Register on the BSB’s website can be found here.

VAT number: 976 1603 02