Edward Hellier

Called 2017

Ed is regularly instructed both as Junior Counsel and in his own right on a wide variety of matters: he has appeared in the Court of Appeal, High Court, and the Tax Tribunals in both direct and indirect tax cases. He also has a busy advisory practice and is instructed by individuals and businesses on anything from domestic SDLT issues to international tax questions.

Prior to joining Chambers Ed read History at Oxford and spent a year in the tax department of a firm of city solicitors. He continues to be an enthusiastic sportsman, although he has come to the realisation that his talents lie more in the courtroom than on the sports field

Among other areas he has experience in:

  • VAT matters including: partial exemption; single and multiple supplies; and reduced rates and exemptions (such as the land exemption and the reduced rate for energy-saving materials);
  • IHT matters including Business Property Relief;
  • SDLT matters including: substantial performance and contracts providing for conveyance to a third party; and Multiple Dwellings Relief;
  • Business rates and council tax;
  • Entrepreneurs’ Relief and the Substantial Shareholding Exemption;
  • Corporation tax matters including those concerning Double Taxation Conventions;
  • Follower Notices and Accelerated Penalty Notices;
  • Penalties; 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.

Current work:

Amongst other matters, Ed is currently working on cases concerning SDLT, VAT on energy saving materials, and capital allowances. He is also involved in a project concerning the taxation of cryptocurrencies and NFTs.


  • 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:

  • 2016: Buchanan Prize, Lincoln’s Inn
  • 2015-2016: Lord Denning Scholarship, Lincoln’s Inn
  • 2014-2015: Lord Brougham Scholarship, Lincoln’s Inn
  • 2014: Hardwicke Scholarship, Lincoln’s Inn

Recent Articles:

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




The Medical Defence Union Ltd v HMRC [2021] UKUT 249 (TCC) – the application of the mutual trading principle in Corporation Tax

UPS SGP Ltd and others v HMRC [2020] UKFTT 242 (TC) – a procedural decision concerning the correct Tribunal in which to determine an SDLT appeal

Greenspace (UK) Ltd v HMRC [2020] UKFTT 349 (TC) – the application of reduced rate VAT to building supplies

Imprimatur Capital Holdings v HMRC [2020] UKFTT 513 (TC) – VAT case concerning input tax recovery by an investment fund

Cape Industrial Services Ltd and Robert Wiseman and Sons Ltd v HMRC [2020] UKFTT 00162– capital allowances on asset leasing and the application of Ramsay

Payne and others v HMRC [2020] EWCA Civ 889 and HMRC v Payne (and others) [2019] UKUT 0090 (TCC) – taxable benefits for Income Tax

HMRC v Tower Resources plc [2021] UKUT 123 (TCC) and Tower Resources v HMRC [2019] UKFTT 442 – VAT input tax recovery by a UK holding company

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 736 – 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; and
  • On a VAT matter concerning security for money that settled before trial.

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