Edward Hellier

Called 2017

Following the successful completion of his pupillage Ed joined Chambers in November 2018.

Prior to pupillage Ed spent a year in the tax department of a firm of city solicitors gaining experience of a corporate tax practice. At 11 New Square he has been involved in litigation and advice in relation to both direct and indirect taxes.

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 IFS’ Tax Law Review Committee and has assisted the research director in that role. He is also a member of the Revenue Bar Association.

Ed 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 Accelerated Payment Notices. He is also involved in a project concerning DAC 6.


  • 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:

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

Recent Articles:

“Multiple Benefits” – Multiple Dwellings relief in SDLT Taxation – January 2019

Taxation VAT article –  How to determine whether a forfeited deposit or payment for an unused supply of goods or services is within the scope of VAT – June 2020

Edward Hellier considers the case of Union Castle, and its impact on transfer pricing and equity transactions – June 2020

COVID-19 Tax Issues – The OECD Checklist, written in collaboration with Francis Fitzpatrick, and Sarah Black.


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

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

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 VAT case concerning input tax recovery by an investment fund. Decision pending; and
  • on a procedural matter concerning the correct Tribunal in which to determine an SDLT appeal. Decision pending.

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