"He is a first-rate advisor and advocate; he removes the mystique from tax law."
Oliver has a practice encompassing all areas of tax law, contentious and non-contentious.
In July 2021, the Chambers HNW guide wrote:
“Oliver Marre is “our go-to when we need advice,” reveals an instructing solicitor, adding: “He’s extremely approachable, knowledgeable and brilliant with clients. Marre often advises high net worth clients on a range of tax matters. Another interviewee enthuses: “What sets him apart, I think, is his ability to relate to clients and explain difficult concepts or strategic points to them. I am always confident in recommending him to clients and colleagues.”
Oliver is also listed in the other main legal directories. This year’s Who’s Who Legal refers to his “strategic prowess”.
As well as his broad general revenue advisory work and litigation, Oliver provides tax advice 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.
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.
Chambers & Partners HNW 2018
Legal 500 2017 Tax
A very considered and approachable adviser.
About Oliver Marre
Oliver is recognised this year as a leading junior in Chambers & Partners, Chambers HNW, Chambers Global, the Legal 500, and Who’s Who Legal.
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.”
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  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  EWHC 4122 (Fam)) or when settlements are being negotiated.
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.
Oliver often advises on the applicability of the DOTAS regime and the GAAR.
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:
- Roulette V2 Charters LLP v Revenue & Customs  UKFTT 537 (TC) (LLP taxation; trading; commerciality; scope of pleadings. Instructed for the Appellants.)
- Lee & Ors v Revenue & Customs  UKFTT 467 (TC)(CGT computation; apportionment; the just and reasonable principle
- Case C-192/16 Fisher v HMRC  (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  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  EWHC 2345 (Ch) (Complex Variation of Trusts Act application. Instructed for 4th, 8th, 9,th & 11th Defendants.)
- Raine v HMRC  TC  UKFTT 0448 (TC) (Beneficial ownership of shares. Instructed for the Appellant.)
- HMRC v Apollo Fuels Limited  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  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  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.
If you were unable to join the webinar a copy of the recording is available to view at your convenience by clicking here.
The slides used during this webinar are also available to view by clicking here.
On 22nd May 2020 Amanda and Oliver recorded a webinar dealing with the current issues in Tax including First Tier and Upper Tribunals during Covid 19.
If you were unable to join this webinar but would like to view the recording at your convenience please click here.
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.
MA (Oxon), English Language & Literature
Chancery Bar Association (member of the Main Committee and editor of the Chancery Bar Review)
Revenue Bar Association