Charlotte Brown

Charlotte advises and represents clients on:

• Tax advisory (corporate & individual tax strategy)

• Capital allowance claims

• VAT: supply issues, characterisation, exemptions, mixed/composite supplies

• Gift Aid claims and treatment in complex scenarios

• HMRC investigations, enquiries, compliance and penalties

• Entrepreneurs’ Relief / Business Asset Disposal Relief

• Estate & succession planning, inheritance tax

• Redress payments related tax liabilities

• Appeals & litigation in First-tier and Upper Tax Tribunals

Charlotte Brown has built a reputation as a tax litigation specialist. Based in Manchester, she accepts instructions nationwide—often directly from businesses or individuals or via advisers.

Background & approach
Charlotte previously operated within the tax litigation divisions of City law firms and a Big 4 firm, giving her deep exposure to how both taxpayers and HMRC operate. She believes in collaborative working with clients, advisers, and legal teams.

She is authorised to conduct litigation, meaning she can manage cases end-to-end—from strategy and drafting to case management and hearing representation. This allows her clients to avoid the administrative burden and procedural complexities of tax disputes.

Illustrative work

• Advised on capital allowances in commercial property context

• Advised a peer-to-peer platform on VAT classification of agency services

• Guided a high-net-worth individual on tax implications of divorce settlements

• Advised a diocesan board on VAT treatment for its supplies

• Advised in long-running Gift Aid enquiries and appeals

• Acted as a s.166 FSMA “skilled person” in a major review of interest rate‐hedging redress issues

• Handled public and private appeals before First-tier and Upper Tribunals, e.g. cases involving excise duty, VAT configuration, personal liability notices

Notable cases

• Michael Coyle t/a Coyle Transport v HMRC — excise duty appeal in UKUT

• Foley v HMRC — oral reconsideration appeal in excise duty

• Revenue & Customs Commissioners v The Ice Rink Co. — VAT characterisation issues on mixed supplies

• Farrow v HMRC — appeal against personal liability notice

• Dodadine (Toucanbox) v HMRC — VAT on boxed supplies

• Logfret (UK) Ltd v HMRC — excise duty issues

• Glover & another v HMRC — out-of-time excise appeals

• Others: Cheshire Centre for Independent Living VAT, Bellavail IMS VAT disputes, Substantia Invest Ltd VAT claims

• Called to the Bar in 2007
•  Tolley’s Taxation Rising Star Award 2018
•  Chartered Institute of Taxation Advanced Diploma in International Taxation (2008)
•  LLM (Tax) King’s College, University of London (2008)
•  LLB King’s College, University of London (2005)
•  Wakefield Girls’ High School (1994-2001)
•  Member of the VAT Practitioners’ Group
•  Member of the Customs Practitioners’ Group
•  Member of the Revenue Bar Association
•  Publications and Seminars
•  Charlotte has written articles for professional publications and presented to professional and lay clients at a number of seminars.