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Emily Campbell

Call: 1995   

+44 (0)20 7306 0102ecampbell@wilberforce.co.uk

Tax

Emily has had an expertise in personal taxation throughout her practice, having taken the Personal Taxation course as part of the BCL degree at Oxford University and sat with members of Chambers specialising in taxation during her pupillage. As an established practitioner, she has lectured in personal taxation at the law faculty in Oxford. She has written numerous articles on tax, including in Private Client Business, the British Tax Review and on the Chambers website. Emily is also a member of the Revenue Bar Association.

The main focus of her tax practice is advisory. In the field of private trusts and estates, she regularly advises on inheritance tax and capital gains tax planning together with other tax issues facing trustees such as income tax (including the pre-owned assets tax) and SDLT. Often this is in conjunction with drafting documentation, such as deeds of variation or deeds of appointment or advancement.

In the field of pensions, she advises frequently on tax issues arising in registered pension schemes, such as unauthorised payments, transitional protections further to the Finance Act 2004, lifetime allowance issues and applications to discharge the scheme sanction charge. Her expertise covers both occupational pension schemes and personal pension schemes (in particular, SIPPs). She also advises on unregistered pension schemes (EFRBS) and other employee benefit arrangements such as EBTs (including issues of disguised remuneration) and excepted group life insurance.

She is increasingly involved in tax litigation and disputes with HMRC, often involving pension schemes. Reported cases include:

  • BAV-TMW-Globaler-Immobilien Spezialfonds v HMRC LTL 5/3/2019 (FTT) (lawfulness of discrimination by registered pension schemes legislation against German quasi- public service schemes); and
  • Barker v Baxendale-Walker [2016] EWHC 664 (Ch) (negligence claim in relation to tax advice regarding an employee benefit trust).