Tic-tax-toe: the winning formula for these masters of tax is a “unique combination of tax knowledge, litigation experience, and client service.”
Tax law. Is it an impenetrable legal labyrinth? Or a juicy intellectual challenge? If you think the latter, you’re in good company. For the pupils at Pump Court Tax Chambers and all those who work there, tax law is a problem solver’s dream. As one pupil shared, “what I like about tax law is that you get to dig deep into technical projects.” The subject matter of cases can be hugely complex, such as the high-profile film finance scheme of Ingenious Film Partners, which HMRC alleged was a tax avoidance scheme. The PCTC team, led by David Milne QC, is defending against the claims in this ongoing case. With over 30 barristers specialising in tax, this set has earned the highest praise possible from Chambers UK with three top-tier tax rankings.
“What I like about tax law is that you get to dig deep into technical projects.”
Senior clerk Nigel Jones says the set is defined by “our unique combination of tax knowledge, litigation experience and client service in an ever-changing field of law with sophisticated and knowledgeable clients.” The client base ranging from magic circle firms to high-street firms for smaller matters. The work chambers does is split into eight distinct areas: corporate tax, personal tax, indirect tax, customs and duties, employee remuneration, professional negligence, stamp taxes and arbitration. Stamp duty land tax cases have been a trend in recent years: in one ongoing case, Roger Thomas QC represented Project Blue as taxpayer regarding its acquisition of Chelsea Barracks for redevelopment, and how much stamp duty is owed to HMRC.
“Covid-19 hasn’t had any disastrous effect on us,” says Jones. “Our advisory work is going strong and everyone has been kept busy.” You might associate tax purely with advisory work, but a junior tenant we spoke to had been so busy with litigation that “it’s more of a fight to make space for the advisory work, to be honest!”
The Pupillage Experience
The set splits its work evenly between direct tax (corporation and business tax), private tax (inheritance, income tax and trusts) and indirect tax (VAT and customs duties). The pupillage is initiated by a ‘bedding in’ period during which pupils sit with one supervisor until the Christmas break. A junior tenant said this “is the core time for learning as much as possible, getting to grips with the work, and looking at different cases, opinions and litigation.” Our senior sources confirmed the aim of the first six is to expose pupils to the typical sorts of matters PCTC works on and prepare them for (hopefully) tenancy. The pupillage committee has actually been toying with the idea of starting the pupillage a couple of weeks earlier than usual for future pupils. “This extra time would give pupils an overview of substantive tax law," says Richard Vallat QC, head of the pupillage committee.
“… analysing the way tax code interacts with European fundamental freedoms.”
Again, this is testament to how technical this area of law is. Pupils may work on jurisdiction review cases or puzzle over double tax treaties. “I was looking at tax in the UK and internationally,” one told us, “analysing the way tax code interacts with European fundamental freedoms.” There are also plenty of chances to go to court in the first six: “I took notes of cross-examinations at the High Court and Court of Appeal.”
The second six is more private client-focused – a junior tenant recalled working on matters involving “inheritance tax, income tax, capital gains tax and wills drafting” throughout. At this point, “the emphasis is on learning about substantive tax law and how to approach litigation,” notes Vallat. The first three months of the second six are divided between two supervisors. At the tail end of the pupillage, pupils go through a fast-track rotation, spending two weeks with three to four different supervisors. During this period, pupils spend their time focusing on one or two tasks. “A supervisor will email you a skeleton argument of a case,” for example, for the pupils to analyse and then provide an opinion.
Additionally, pupils undergo two assessed moots around Easter time. PCTC’s most recent pupils were given a question referring to the Court of Justice in Luxembourg, which we heard is a “classic type of question” in these assessments. Understandably the moots can be quite intense, not least because they’re open to all members of chambers to come and watch, but “if you like advocacy, it’s quite exciting really.”
The tenancy decision is made in July. Taking into account supervisor feedback as well as the assessed advocacies, the pupillage committee grades pupils out of ten, with scores of eight and above being the sweet spot. In 2019, neither made the cut. “This does sometimes happen if we don’t feel either are a fit,” says Vallat, “but if both pupils are excellent we would also take both.” In 2020, one of two pupils became tenants. The set doesn’t leave unsuccessful pupils without support. “We help them work out their next steps, whether that be another tax set, a law firm or elsewhere,” says Vallat. “It’s fair to say it’s harder to go from a tax set to a non-tax set.”
“You get the impression that people want to help you.”
Pupils who’re offered tenancy are encouraged to take it easy in the months from July to September, as “once they start, the work can be relentless,” Vallat cautions. An average working day for PCTC pupils runs from 9am to 6pm, but late stays and weekend work aren’t unheard of. “It’s hard work so sometimes I will stay later, but I’ll always have time for lunch and a coffee,” one pupil reassured us. Colleagues bond over the sweet smell of caffeine during chambers coffee every morning at 11am. “It’s an important feature at the set,” juniors explained. “You get to ask questions and talk about recent developments and tax issues.” Catch-ups also take place over lunch, as Pump’s people often take a trip to one of the various local inns for a bite to eat.
Junior sources told us much of the set’s culture and socialising revolves around mentorship, both professionally and personally. “You get the impression that people want to help you,” they said. “We have a studious, refreshing, and supportive atmosphere.” Through a formal mentorship programme, pupils have a panel of people they can run to with any questions. Members often attend seminars and networking events together, including a programme called ‘meet the juniors.’ As senior clerk Nigel Jones explains, “we usually take half a dozen juniors along and give soundbite presentations with drinks and canapés after.”
The Application Process
The set’s application process kicks off with a CV and covering letter, which is treated as a form of advocacy: clear and concise writing comes off well. Although tax experience isn’t required, applicants do need to have an interest in tax legislation and be able to explain why they’re interested in the Tax Bar. Around 20 applicants are invited to the first-round interview, where interviewees are given around 15 minutes to read through a piece of statute to discuss during the 30-minute interview. The interview is marked for technical analysis and how willing candidates are to defend and change their answers when pressed. “We try to bring out the best in people as opposed to scaring them,” says Vallat.
“We don’t need candidates to come in over-polished – we look for normal people!”
From here, the top ten candidates are asked to submit a written tax opinion in the space of eight hours. “This task is intended to enable a deeper process of thinking and allow different strengths to come to the fore,” says Vallat. A junior tenant reflected on their taxing day: “It’s inherently stressful, but you also get to have a good crack at showing what you’re made of!” Based on the anonymised opinions, the panel invites up to five candidates back to the final-round interview, where they orally defend their work.
Vallat outlines what the set scouts for throughout the application process: “We are looking for technical ability, the ability to engage with statutory language, solid academic credentials, and persuasive speaking.” But not to fear, the odd slip won’t rule you out: “We don’t need candidates to come in over-polished – we look for normal people!”
Tax to the max: PCTC puts on tax master classes for anyone looking to brush up – you can register your interest in the next event by emailing the set.
Pump Court Tax Chambers
16 Bedford Row,
- No of silks 12
- No of juniors 22 (9 women)
- No of pupils 1-2 in any given year
- Contact Barbara Belgrano & Edward Waldegrave, [email protected]
- Method of application Pupillage Gateway
- Deadline: Pupillage Gateway deadline (expected to be February 2021)
- Pupillages (pa) Up to 2, funded
- Tenancies in last three years 3 new tenants in last three years
Type of work undertaken
Pupils will work with at least three pupil supervisors in their first six months and will also sit with other members of chambers so as to receive a broad training in most aspects of Chambers’ work. Tenancy decisions are usually made in July.
Chambers offers funded mini-pupillages. The programme runs throughout the year. Applications should be made via email to [email protected] with accompanying CV and marked for the attention of the Mini-Pupillage Secretary.
See https://www.pumptax.com/pupillage/mini-pupillage/ for further details including deadlines.