One minute with Rebecca Murray, Barrister at Devereux Chambers
What’s keeping you busy at work?
A mixture of the Government’s most complex tax cases and advice, on the Attorney General’s A-panel of counsel, and private complex cases and advice for companies and individuals.
Last year, this included a win for HMRC in the Court of Appeal in AD Bly Groundworks v HMRC [2025] EWCA Civ 1443 in respect of the question whether expenditure was ‘wholly and exclusively for the purposes of the trade’ or had the dual purpose including a more than incidental aim of obtaining a corporation tax deduction. I appeared as sole counsel for HMRC in that case and two other appeals in the private client sphere, one on business investment relief which is coming up to the Court of Appeal later this year, and one on transfers of assets abroad.
I recently appeared as sole counsel for the taxpayer in an IHT appeal on whether expenditure on political donations to organisations campaigning in the Referendum on Brexit was ‘normal expenditure out of income’ and thereby exempt from the charge to IHT on chargeable lifetime transfers, or alternatively whether the exemption in IHTA 1984 s 24 is discriminatory when it comes to these transfers. It is a greatly anticipated decision.
What do you know now that you wish you’d known at the start of your career?
That my differences are nothing to be ashamed of; rather, they are strengths.
If you could make one change to tax, what would it be?
I am not usually one to propose changes to tax law, but I have never seen tax law have such a dramatic and tragic effect on the economy as those in 2024/25. It would have to be these two things: a policy to attract back to the UK the 10,800 millionaires, 78 centi-millionaires and 12 billionaires who left the UK in 2024/25 as a result of the IHT changes; and reductions in income tax and NIC, the hiking of which has caused well-established businesses to close and leave the UK.
Why? Well, the fact that HNWIs have moved has impacted many business sectors: property (London house prices at their lowest in two years in November 2025) and retail (in London, 13,479 stores closed in 2024 – the equivalent of 37 each day, a 28% increase on 2023 closures).
Put simply, HNWIs create jobs which no longer exist; and hikes in NIC from 13.8% to 15% in 2025 mean that nurseries, retail, hospitality, small businesses and the care sector have cut jobs, closed or moved abroad as well.
These individuals have now set up their lives elsewhere. To undo that effect would require tax policies which serve as a bold attraction for HNWIs to move to, and encourage work in, the UK. A U-turn on the non-domicile IHT changes will not achieve that alone. There must be attractive tax and national insurance rates which serve as an incentive for them to return from the places they have dispersed to, such as Switzerland, Abu Dhabi and Dubai.
Was there anything in the Finance Bill that caught your eye?
The changes relating to promoters of tax avoidance schemes and HMRC’s enhanced powers for tackling tax-advisers facilitated non-compliance, on which I spoke at the CIOT residential Conference in 2025. The latter give HMRC extremely broad and draconian powers, including new criminal offences. These will have a big impact in due course.
Finally, you might not know this about me but...
I may be the only barrister who hates wearing black and gets an instant headache from wearing a wig. Given the choice, I like to wear gold – and nothing larger than a tiara on my head.
One minute with Rebecca Murray, Barrister at Devereux Chambers
What’s keeping you busy at work?
A mixture of the Government’s most complex tax cases and advice, on the Attorney General’s A-panel of counsel, and private complex cases and advice for companies and individuals.
Last year, this included a win for HMRC in the Court of Appeal in AD Bly Groundworks v HMRC [2025] EWCA Civ 1443 in respect of the question whether expenditure was ‘wholly and exclusively for the purposes of the trade’ or had the dual purpose including a more than incidental aim of obtaining a corporation tax deduction. I appeared as sole counsel for HMRC in that case and two other appeals in the private client sphere, one on business investment relief which is coming up to the Court of Appeal later this year, and one on transfers of assets abroad.
I recently appeared as sole counsel for the taxpayer in an IHT appeal on whether expenditure on political donations to organisations campaigning in the Referendum on Brexit was ‘normal expenditure out of income’ and thereby exempt from the charge to IHT on chargeable lifetime transfers, or alternatively whether the exemption in IHTA 1984 s 24 is discriminatory when it comes to these transfers. It is a greatly anticipated decision.
What do you know now that you wish you’d known at the start of your career?
That my differences are nothing to be ashamed of; rather, they are strengths.
If you could make one change to tax, what would it be?
I am not usually one to propose changes to tax law, but I have never seen tax law have such a dramatic and tragic effect on the economy as those in 2024/25. It would have to be these two things: a policy to attract back to the UK the 10,800 millionaires, 78 centi-millionaires and 12 billionaires who left the UK in 2024/25 as a result of the IHT changes; and reductions in income tax and NIC, the hiking of which has caused well-established businesses to close and leave the UK.
Why? Well, the fact that HNWIs have moved has impacted many business sectors: property (London house prices at their lowest in two years in November 2025) and retail (in London, 13,479 stores closed in 2024 – the equivalent of 37 each day, a 28% increase on 2023 closures).
Put simply, HNWIs create jobs which no longer exist; and hikes in NIC from 13.8% to 15% in 2025 mean that nurseries, retail, hospitality, small businesses and the care sector have cut jobs, closed or moved abroad as well.
These individuals have now set up their lives elsewhere. To undo that effect would require tax policies which serve as a bold attraction for HNWIs to move to, and encourage work in, the UK. A U-turn on the non-domicile IHT changes will not achieve that alone. There must be attractive tax and national insurance rates which serve as an incentive for them to return from the places they have dispersed to, such as Switzerland, Abu Dhabi and Dubai.
Was there anything in the Finance Bill that caught your eye?
The changes relating to promoters of tax avoidance schemes and HMRC’s enhanced powers for tackling tax-advisers facilitated non-compliance, on which I spoke at the CIOT residential Conference in 2025. The latter give HMRC extremely broad and draconian powers, including new criminal offences. These will have a big impact in due course.
Finally, you might not know this about me but...
I may be the only barrister who hates wearing black and gets an instant headache from wearing a wig. Given the choice, I like to wear gold – and nothing larger than a tiara on my head.
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