Among other areas he has experience in:
- VAT matters including: partial exemption; single and multiple supplies; and reduced rates and exemptions;
- Corporation tax matters including: capital allowances, R&D reliefs, and mutual trading;
- International tax issues including: application of double taxation conventions, and appearance in international arbitration;
- Partnership taxation;
- Chargeable gains matters including degrouping charges;
- Individual taxation matters including: the TiS regime, taxable benefits, income classification, and pensions;
- SDLT matters including: substantial performance and contracts providing for conveyance to a third party; higher rates; and dwellings;
- Judicial review; and
- Procedural matters and the application of the TMA 1970.
Ed is a member of the Revenue Bar Association, and has previously been a member of the IFS’s Tax Law Review Committee. He accepts instructions to act and advise on the full range of Chambers’ practice areas both as Junior Counsel and on his own.
Supreme Court
- News Corp UK & Ireland Ltd v HMRC [2023] UKSC 7 – the application of the zero rate in VAT. Concerning broader issues of statutory interpretation, including the always speaking principle.
Court of Appeal
- HMRC v Altrad Services Ltd [2024] EWCA Civ 720 – capital allowances on asset leasing and the application of Ramsay
- BlueCrest Capital Management LP and others v HMRC [2023] EWCA Civ 1481 – taxation of partnerships and miscellaneous income.
- HMRC v LG Park HT1 Ltd & ors [2023] EWCA Civ 1193 – the transfer of market value to the Land Chamber in SDLT proceedings
- BCM Cayman LP & Anor v HMRC [2023] EWCA Civ 1179 – taxation of partnerships and loan relationships
- Greenspace (UK) Ltd v HMRC [2023] EWCA Civ 106 – the application of reduced rate VAT to building supplies.
- Payne and others v HMRC [2020] EWCA Civ 889 – taxable benefits for Income Tax.
Upper Tribunal
- Sajedi and others v HMRC UT-2025-000085 – SDLT commencement provisions and higher rates. Appeal allowed and FTT decision remade by consent order
- Osmond and another v HMRC [2025] UKUT 183 (TCC) – TiS regime and application of the purpose test
- HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) – withholding tax on interest under the UK-Irish double tax treaty
- Altrad Services Limited, and Robert Wiseman and Sons LTD v HMRC [2022] UKUT 00185 (TCC) – capital allowances on asset leasing and the application of Ramsay.
- LG Park GT1 Ltd v HMRC [2022] UKUT 00178 – a procedural decision concerning the correct Tribunal in which to determine an SDLT appeal.
- The Medical Defence Union Ltd v HMRC [2021] UKUT 0249 (TCC) – the application of the mutual trading principle in Corporation Tax.
- HMRC v Tower Resources plc [2021] UKUT 0123 (TCC) – VAT input tax recovery by a UK holding company.
First-tier Tribunal
- Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC) – R&D Relief and discovery assessments
- Currys Retail Ltd v HMRC [2025] UKFTT 762 (TC) – goodwill and corporate degrouping charges
- Global By Nature v HMRC [2025] UKFTT 24 (TC) – application of VAT zero-rate
- Sajedi and others v HMRC [2025] UKFTT 297 (TC) – SDLT commencement provisions and higher rates
- The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC) – capital allowances on plant and machinery and the application of Lists B and C
- CATS North Sea Ltd v HMRC [2024] UKFTT 512 (TC) – ring fence trade, capital allowances and transfer of trade provisions
- FC Shipping Ltd v HMRC [2024] UKFTT 1013 (TC) – tonnage tax and financing arrangements
- Collins v HMRC [2024] UKFTT 00951 (TC) – application of R&D relief in Corporation Tax.
- United Biscuits v HMRC [2023] UKFTT 864(TC) – the application of the zero rate to food.
- Lyons v HMRC [2023] UKFTT 00294 (TC) – residence and CGT.
- Batten v HMRC [2022] UKFTT 00199 (TC) – interaction of the statutory residence test and the common law residence test.
- Dower v HMRC [2022] UKFTT 170 (TC) – the application of the multiple dwellings relief in SDLT.
- Metropolitan International Schools Ltd v HMRC [2021] UKFTT 438 – an appeal against an information notice.
- Imprimatur Capital Holdings v HMRC [2019] UKFTT 0736 (TC) – VAT case concerning input tax recovery by an investment fund.
- Anna Cook v HMRC [2019] UKFTT 0321 (TC) – application of the private tuition exemption in VAT to dance classes.
- Romima Ltd (and others) v HMRC [2019] UKFTT 0736 – VAT case concerning vouchers.
In addition Ed has been instructed:
- In a case concerning VAT partial exemption. Settled before trial;
- On Accelerated Payment Notice matters;
- On a taxpayer Judicial Review;
- On a VAT matter concerning security for money that settled before trial; and
- International arbitration concerning tax treaty stabilisation measures.
Chambers and Partners 2026
“Edward is a superb junior who is bright and works very hard.”
“Edward is an exceptional junior. He’s strong in his analysis and delivery, and has excellent lay and professional client-handling skills.”
“He’s a personable, fun guy to be around and work with. His drafting and attention to detail are excellent.”
“Edward Hellier is very responsive and has an excellent bedside manner. He is able to digest complex fact patterns quickly and produce compelling arguments.”
“Edward is a very good lawyer and a good litigator. We’ve done some complex things with Edward and he’s shown himself to be very bright and able.”
“Edward is very into the details of each case, whether factual or technical, and is very good to work. He has an open working style, which makes it feel as though he’s part of the team.”
Chambers and Partners 2024.
‘‘Highly organised and very bright, he is an up and coming talent”
Legal 500 (2024).
‘‘Hands-on, brilliant attention to detail, responsive and very capable”
- 2015-2016: City Law School, City University London; BPTC (Outstanding)
- 2014-2015: City Law School, City University London; GDL (Distinction)
- 2010-2013: Oxford University; BA (Hons) History (Prelims, Distinction)
Scholarships and Prizes:
- 2015-2016: Lord Denning Scholarship, Lincoln’s Inn
- 2014-2015: Lord Brougham Scholarship, Lincoln’s Inn
- 2014: Hardwicke Scholarship, Lincoln’s Inn
- 2016: Buchanan Prize, Lincoln’s Inn
- Supreme Court rules on zero-rating – 11 New Square
- COVID-19 Tax Issues – The OECD Checklist, written in collaboration with Francis Fitzpatrick, and Sarah Black.
- Edward Hellier considers the case of Union Castle, and its impact on transfer pricing and equity transactions – June 2020
- Edward Hellier considers the case of Union Castle, and its impact on transfer pricing and equity transactions – June 2020
- “Multiple Benefits” – Multiple Dwellings relief in SDLT Taxation – January 2019