Oliver Marre
Junior counsel

Oliver Marre

Call to Bar:2011


“He is extremely intelligent and forensically thorough in his analysis of both the facts and the legal principles involved. A real star."

Oliver has a practice encompassing all areas of tax law, contentious and non-contentious.

In recent years, he has been described as “a leading light of his generation” by the Chambers & Partners directory, “extremely intelligent” and “a real star” by the Legal 500, and “our go-to” barrister and “brilliant with clients” by Chambers HNW.  Who’s Who Legal has commented on his “strategic prowess”.

As well as his broad general revenue advisory work and litigation, Oliver provides tax advice (onshore and offshore) in the contexts of trusts disputes, mediations, in cases before the Family Division (including complex or HNW divorce cases) and in relation to the taxation of charities and charitable donors.

5 Stone Buildings - building sign
Legal 500 2024

“Oliver has a unique ability to make the most complex tax analyses seem simple.”

Chambers & Partners UK Bar 2023

An excellent track record advising high net worth individuals.

Legal 500 2023

An exceptional communicator. Extremely sharp, extensive and deep knowledge.

Chambers HNW 2022

Pragmatic, expert tax advice in an accessible style

Legal 500 2022

The best service and most thorough, practical advice to us and our clients.

Chambers & Partners UK Bar 2022

Very approachable, highly knowledgeable and brilliant with clients.

Legal 500 2021

Incredibly bright and extremely knowledgeable

Chambers and Partners HNW

The breadth of his expertise is really impressive...He is an excellent communicator, altogether a pleasure to work with, and he is incredibly reliable and supportive

Legal 500 2020, Private Client Personal Tax

Is an excellent communicator, has a practical and commercial approach and is very accessible.

Legal 500 2020, Corporate Tax

He is a first-rate advisor and advocate; he removes the mystique from tax law.

About Oliver Marre

Professional reputation

Oliver is recognised this year as a leading junior in Chambers & Partners, Chambers HWN, Chambers Global, the Legal 500 and Who’s Who Legal.

Chambers & Partners (2024, tax): “Oliver is one of the leading lights of his generation. He is passionate about his work and obviously very bright and focused on what he does.”

Chambers & Partners (2024, private client tax): “Oliver has great judgement and pursues cases tactically. He has really good knowledge on tax law.”

Legal 500 (2024, corporate tax): “Oliver has a unique ability to make the most complex tax analyses seem simple. He is personable and technically excellent; he inspires confidence and is a thoroughly nice person with whom to work.”

Legal 500 (2024, private client tax): “He is extremely intelligent and forensically thorough in his analysis of both the facts and the legal principles involved. A real star.”

Chambers HNW (2023): “Oliver has always demonstrated an understanding of our clients’ positions which is crucial to gaining their trust and in implementing his recommended solutions.”

Who’s Who Legal (Private Client, 2023): “He combines a keen technical knowledge with an ability to explain complex issues in clear language with a commercial approach.”

Chambers Global (2023): “Oliver Marre assists clients with complex contentious and non-contentious tax matters. His work includes advising on inheritance tax planning and trusts, and he also tackles tax issues arising from high-value divorce proceedings.”

Chambers & Partners UK Bar (2023): “Oliver Marre advises corporate clients on a broad array of tax matters, and has notable experience and expertise advising investment funds and charities. He also has an excellent track record advising high net worth individuals in tax matters. ‘Produces efficient, comprehensible advice on highly technical tax matters.’”

Legal 500 (2023, private client tax): “Oliver is an exceptional communicator. His written advocacy skill is very good.”

Legal 500 (2023, corporate tax): “Extremely sharp, extensive and deep knowledge. A clear communicator. Extremely accessible style and puts clients at ease. Pleasure to work with”.

Oliver won the UK Private Client category Lexology Client Choice award in November 2022. Established in 2005, these awards recognise practitioners around the world, who stand apart for the excellent client care they provide and the quality of their service. They are awarded solely on the basis of client research.

Who’s Who Legal (2022): Oliver Marre is renowned for his “impressive breadth of knowledge and impressive communication skills”, as well as his “strategic prowess”. One source adds, “He is my go-to barrister in the area.”

Chambers UK Bar (2022): “Very approachable, highly knowledgeable and brilliant with clients.” “He is very good at rapidly getting to the core of a brief and selecting the relevant points.”

Legal 500 (2022): “He tackles everything with great enthusiasm. Oliver is very responsive and always strives to provide the best service and most thorough, practical advice to us and our clients.”

Chambers HNW (2021): “our go-to when we need advice” “Extremely approachable, knowledgeable and brilliant with clients.”  “What sets him apart is his ability to relate to clients and explain difficult concepts or strategic points to them.  I am always confident in recommending him.”

Chambers Global (2021): “He is an excellent communicator who is a pleasure to work with and incredibly reliable and supportive.”

Legal 500, private client: personal tax (2021): “incredibly bright and extremely knowledgeable in relation to the complexities of personal tax law – he is particularly able to take highly complex taxation issues and translate these comfortably for the lay client to understand.”

Legal 500, corporate tax (2021): “Excellent at legal analysis, a good manner with clients and he is highly responsive.”

In July 2020, Chambers HNW wrote: “The breadth of his expertise is really impressive, he provides thorough and practical advice and he offers solutions and thinks around the problem, he doesn’t just answer the questions he is asked,” observes an instructing solicitor. The source continues: “He is very attentive and enthusiastic, and he has taken a real interest in our clients’ situations. He is an excellent communicator, altogether a pleasure to work with, and he is incredibly reliable and supportive.”

For Private Client work, the Legal 500 (2020) said Oliver “is an excellent communicator, has a practical and commercial approach and is very accessible” and for Corporate Tax work, it noted that “he is a first-rate advisor and advocate; he removes the mystique from tax law.”

The previous year, the Legal 500 recommended Oliver as “a rising star” for Private Client tax and commented that, for Corporate tax, he has “a strong advisory practice”.

Chambers & Partners (2019): Oliver “assists clients with complex contentious and non-contentious tax matters … he’s very measured in his approach to advising and he gives a balanced, credible opinion.”

Chambers HNW (2019):  “Oliver Marre has a strong private client tax advisory and litigation practice. “I’ve used a number of tax counsel and what a lot of them tend to do is talk a lot, because it’s a very technical area,” says an interviewee, who adds that, with Marre, “what we found is if we ask for a one-word answer he will give it to you; he cuts through the jargon and gives you a simple answer. It’s built upon his extensive knowledge, but in the heat of negotiations he’s happy to cut through the chat and get to the point. He’s very, very good at being concise.”

In 2018, Chambers & Partners commended Oliver’s “user-friendly” approach and the Legal 500 described him as “a very considered and approachable advisor”.

In 2017, the Legal 500 also ranked Oliver as a leading practitioner with reference to his “clear, detailed and carefully thought-out advice.”

In 2016, he was nominated as a Rising Star by Taxation magazine.

Private client

Oliver has particular interest in private client taxation, both at the planning stage and in cases where a dispute or difference of opinion has arisen with HMRC. He is recognised as a leading practitioner in this area by the Chambers & Partners, Chambers HNW and the Legal 500.

In recent months, Oliver’s work has included advice in respect of:
• Domicile and residence
• The remittance basis
• The transfer of assets abroad legislation, the ITTOIA settlements legislation and sections 86 and 87 TCGA 1992 including the recent legislation for protected trusts
• Other areas of trust taxation (both onshore and offshore), including de-enveloping issues
• The taxation of benefits from trusts and employers, including company cars, chattels leasing and loans
• Employment income generally, including payments on loss of office, debts/loans and national insurance contributions
• The taxation of land transactions
• Inheritance tax planning and reliefs including business property relief and agricultural property relief
• The taxation of charities.

In addition, Oliver has advised on Variation of Trusts Act applications (e.g. Pemberton v Pemberton [2016] EWHC 2345 (Ch)) and rectifications.

Oliver also enjoys working on tax aspects of family law disputes, whether in court (e.g. Cooper-Hohn v Hohn [2014] EWHC 4122 (Fam)) or when settlements are being negotiated.

Tax advisory

Oliver’s tax advisory work covers all areas of direct and most areas of indirect taxation. He is recognised as a leading practitioner for both private client and corporate tax work by the legal directories, with references to his “strong advisory practice” (Legal 500), his “measured approach” (Chambers & Partners) and his “balanced, credible” opinions (Chambers HNW).

As well as income tax, capital gains tax, and inheritance tax advice for individuals, trustees and partnerships, Oliver advises entities (including companies and trading LLPs) on the Corporation Tax acts and generally on SDLT legislation and on VAT. He takes a special interest in advising charities and philanthropic donors.

He undertakes a significant amount of advisory and litigation work for clients operating in the investment management, alternative asset management, and private equity industries on issues relating to carried interest, partnership/LLP structuring, and corporate residence/permanent establishment questions.

Oliver often advises on the applicability of the DOTAS regime and the GAAR.

Tax litigation

Oliver is “a first-rate advocate” who “removes the mystique from tax law” (Legal 500).

Oliver’s contentious tax work falls into three main parts, although they are not always distinct.

First, pure tax disputes between taxpayers and HMRC. In many cases, Oliver’s aim will be to ensure a satisfactory resolution, taking into account HMRC’s Litigation and Settlement Strategy, without needing to appeal to the courts or tribunals. When necessary, however, Oliver will represent (either led or as sole counsel) taxpayers before any court or tribunal and he has experience from the First-tier Tribunal to the Court of Justice of the European Union. Oliver also has experience of negotiating/litigating in respect of historic tax avoidance schemes, challenges to DOTAS notifiability and penalties disputes.

Secondly, public law disputes, when taxpayers are challenging HMRC’s exercise of their powers. Recent work in this area includes challenges to the exercise of powers to issue Accelerated Payment Notices, Follower Notices and disputes around the creation by HMRC of a legitimate expectation. Oliver has also recently enjoyed success on public law grounds without needing to litigate.

Thirdly, Oliver has been involved in the tax aspects of family law proceedings, including the country’s highest value reported divorce case, and the tax aspects of major charity disputes. Similarly, Oliver has played the role of tax counsel in inter partes trust and charity negotiations and litigation.

Recent cases of particular interest include:

  • HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 00232 (TCC) (HMRC’s appeal on LLP taxation, salaried members rules, significant influence test, asset management industry.  Instructed for BlueCrest.)
  • BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) (LLP taxation, salaried members rules, significant influence test, asset management industry.  Instructed for the Appellant.)
  • Roulette V2 Charters LLP v Revenue & Customs [2019] UKFTT 537 (TC) (LLP taxation; trading; commerciality; scope of pleadings. Instructed for the Appellants.)
  • Lee & Ors v Revenue & Customs [2019] UKFTT 467 (TC)(CGT computation; apportionment; the just and reasonable principle
  • Case C-192/16 Fisher v HMRC [2017] (CJEU on the constitutional status of Gibraltar; EU treaty freedoms, in particular freedom of establishment and free movement of capital; scope of the wholly internal rule. Instructed by the Government of Gibraltar.) Also in FTT and, on procedure (to date), in the UT.
  • Lee & Bunter v HMRC [2017] UKFTT 279 (FTT on the characterisation of a trust for OECD treaty purposes; round the world CGT planning. Instructed for the Appellants.) Also related High Court proceedings (pending).
  • Pemberton v Pemberton [2016] EWHC 2345 (Ch) (Complex Variation of Trusts Act application. Instructed for 4th, 8th, 9,th & 11th Defendants.)
  • Raine v HMRC [2016] TC [2016] UKFTT 0448 (TC) (Beneficial ownership of shares. Instructed for the Appellant.)
  • HMRC v Apollo Fuels Limited [2016] EWCA Civ 157 (Income tax benefits code; meaning of benefit; property in a chattels lease. Instructed for the Appellants.) Also in FTT and in the UT, and successful costs application.
  • Cooper-Hohn v Hohn [2014] EWHC 4122 (Fam) (UK’s largest reported divorce. Instructed for the Wife.)

Much of Oliver’s tax work has an offshore element. In particular, he takes a special interest in the UK tax aspects of complex offshore structures including trusts and holding companies.

He is often instructed to provide expert Opinions on English tax law for use in proceedings in off shore jurisdictions (e.g Re The Grundy Trust [2020] JRCO71)

Recent work includes advising on

  • Offshore holding structures for UK assets
  • Offshore holding structures for non-UK domiciled UK residents
  • Offshore evasion/disclosure penalties and obligation
  • Situs of assets
  • The tax treatment of foreign law entities including overseas foundations.

Oliver has also advised on the availability of EU law defences to UK tax charges and represented HM Government of Gibraltar in Fisher.

Oliver has lectured internationally on offshore UK tax issues including in Jersey, Gibraltar and Dubai.

Publications and lecturing

Oliver contributes the chapters on High Net Worth taxation and taxation on divorce/separation to Tolley’s Tax Planning.

He was co-author of the 9th and 10th editions of the Taxation of Charities and has been online moderator of James Kessler QC’s Taxation of Nonresidents and Foreign Domiciliaries.

Oliver also lectures regularly and has spoken for STEP and the CIOT as well as delivering seminars for commercial providers.

Recent topics have included:
• Protected trusts
• Inheritance tax on residential property
• Cleansing/rebasing for new deemed UK domiciliaries
• Tax for divorcing non-doms
• Inheritance tax planning
• DOTAS and the GAAR.

He is happy to provide in-house seminars to client firms.

Education and qualifications

MA (Oxon), English Language & Literature
PgDL (City)
BPTC (City)

Professional memberships

Chancery Bar Association (member of the Main Committee and editor of the Chancery Bar Review)
Revenue Bar Association

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