Direct Access Barrister
Ximena Montes Manzano
Direct Access Barrister
Ximena Montes Manzano
Highly regarded tax litigator. Wide experience of group litigation and representation of taxpayers in multi-day proceedings in the tax tribunals and higher courts (including Judicial Review challenges against HMRC).
Strategic and tactical advice provided in disputes against HMRC.
Very commercially minded and fully conscious that litigation is a lengthy and expensive process and as a result will advise clients on the best route to resolve issues. Will explain in simple terms the advantages and disadvantages of mediation, formal complaints to HMRC/ Adjudicator/Ombudsman, appeals and Judicial Review.
Area of Law
Tax and Revenue
Appeals to Tax Tribunals and Higher Courts, Judicial Review. Support with ADR and formal complaints.
What sort of work do I do?
Personal, business, corporate, partnership tax and VAT/ SDLT. Some experience of private client tax (business/agricultural property relief; 10-year and exit charges for trusts and EBTs).
Extensive experience of cases involving the administration and collection of tax (validity of Notices of Enquiry, Closure Notices, time limits, Information Notices, Discovery Assessments, etc.)
Recent successes include defending taxpayers who participated in historical EBT/ contractor loan arrangements against unreasonable and disproportionate information notices and substantial penalties for alleged deliberately inaccurate returns.
I also have conduct of a number of high-profile IR35 appeals and I recently appeared as junior counsel for Atholl House Productions Ltd (Kaye Adams) in the Court of Appeal and I am currently instructed in the remittal of the case to the Upper Tribunal.
Particular expertise of defending penalties (for inaccuracies, failure to file, failure to pay on time, entering into schemes, failure to disclose) and the application of statutory and policy-led mitigation.
Previous experience of Agent Conduct Notices, Promoters of Tax Avoidance Conduct Notices and Promoters of Tax Avoidance Monitoring Notices.
Who do I work for?
Clients include corporates, partnerships, owner-managed businesses, media personalities and HNW individuals.
Feedback from clients commend my "remarkable" attention to detail, common sense approach and commercial insight when providing advice and throughout the course of litigation.