Yes! You Can Win. All you need is that stubbornly resilient self, hidden deep within you. All your life is a journey to bring that leader to the fore, for the world to admire, and for yourself to achieve whatever you dreamed of.
The story of Rebecca Murray―presently a Tax Barrister at Devereux Chambers―is the best example of that. Her career path has not been a straight road; it has been ruled by her instincts at every stage. She did maths, physics, and chemistry for A-levels, but apart from wanting to fly into space, she couldn’t imagine a career in science. So she did something she saw as practical and versatile at university: a law degree at King’s College London, followed by Bar School.
Tax Saved Her
Rebecca did not enjoy her law degree at all until she studied tax in her final year, and things fell into place. “I wanted security and a home, something I had not had growing up,” she states. You don’t get that at the Bar, the income is not stable, and there is no guarantee of work so that you couldn’t get a mortgage. She applied to some accountancy firms. “I didn’t think that the Big Five were for me, I’m not a fan of large corporate beasts, and they seemed to pigeonhole graduates into highly specialized areas within tax, like “preparing gross up calculations for ex-pat tax returns”. They sounded both dull and daunting. So Rebecca decided to apply to the smallest one, Arthur Andersen, and to some mid-tier firms. She had two offers, one from Arthur Andersen and one from Grant Thornton. “I loved the recruitment process at Grant Thornton and could see they invested so much into their graduates that it felt like the right fit (I hate to say it, but Andersen’s felt misogynistic even during the interview process)”.
There, Rebecca obtained the ATT and CTA qualifications and experienced a few different departments, latterly as a Manager in National Tax, which involved a variety of technical client work and training for the firm. She felt like it was time to try a wholly new market, and a job came up at JPMorgan in the summer of 2006. So, she took that leap and was very quickly promoted to Vice President after working on some very large transactions.
The Itch to Find Her Own Voice
“I was itching to get out of the corporate environment and find my own voice,” shares Rebecca, who left her role as the youngest Vice President at JP Morgan, author of “Corporation Tax” for CCH, trusting she was meant to be at the Bar without any sign of a pupillage.
A few months and many rejections later, Temple Tax Chambers advertised for one, and after a tough few days of interviews and written work, Rebecca was offered it. She felt completely vindicated in her trust of the universe. “However, my pupil master told me on my first day in a tone of bitter disappointment, that a ‘friend’ who he desperately wanted as a pupil was rejected in favour of me”. They all made it clear they were distinctly unimpressed with her education: everyone in chambers went to Oxbridge, and the then Head of Chambers, Richard Bramwell QC, told Rebecca she was wasting her time trying to get to the Bar with those academics (oh, and also that women could not be successful at the Bar). She worked round the clock and did everything they threw at her to a gold star standard and got no feedback (or pay, beyond the minimum pupillage award of £1,000/month, less than the minimum wage!). Pupillage was a tough time in her personal life as well: Her dad went into an induced coma after a heart by-pass went wrong (Rebecca was devastated, and also took responsibility for organizing and funding her younger sister’s wedding and visiting him in hospital each day); her now husband had recently divorced and his ex-wife who was a barrister at that time was not only telling everyone she knew professionally (inter alia!) that Rebecca was a joke for pursuing a career at the Bar as she didn’t go to Oxford like her; and she had refocused her well-honed skills of relentless “woe is me” monologues and manipulation, on to teaching her children to hate Rebecca, who adds, “And trying to control our lives. I was nevertheless trying twice a week to set an example to them, despite that and the long hours of thankless slog. Honestly: at that point, the life and career I thought was meant for me, felt out of reach”.
The Lifeline
Then Rebecca received a professional lifeline… in what was actually intended for her as a poisoned chalice to make her fail very publicly! It is rare for pupils to run their own case. But when her first case was handed to her by a member of chambers who had told the client (set to lose his house if he lost) that it was hopeless, and since he expected to lose, why not let the pupil lose it instead? “I saw it as my only real opportunity to prove they had underestimated me”. The Appellant, Mr Evans, was a general commissioner who had been paying his wife for administrative duties in order to utilize her annual exemption from income tax. HMRC’s witnesses included a general commissioner who gave evidence about the nominal workload of Mrs Evans at his hearings, including a very thick old-fashioned rota to back it up. Rebecca set about examining the evidence, determined to find a way through. She realized that their witness was barely at work himself, a fact she later used in cross-examination to discredit his account. She saved the Evans’ from selling their home to pay the tax and penalties they appealed against, and it gave them a happy retirement. After that case and doing advisory work for every single member of chambers, Rebecca got tenancy in 2010. It was a true test of self-belief in the face of adversity. “I learnt to follow my instincts and that we are all surrounded by prejudice, toxicity, spin, and just plain lies. You have to have your own moral compass”.
Rebecca set about building her own practice and reputation and getting her second book, “Tax Avoidance,” published. “I particularly enjoyed Chambers’ astonishment when I was on the winning side of my first big cases, Tower MCashback v HMRC [2011] UKSC 19 and Eclipse Film Partners (No 35) LLP v HMRC [2012] UKFTT 270, which made the front page of the Times in 2012 and went up to the SC”.
Making a Difference
According to Rebecca, many unique skills and approaches are essential for a barrister to have in order to be successful in high-stakes tax litigation. She is constantly learning new laws and procedures, and with the facts of a new case, she leaves no stone unturned. She seeks first to understand, then to be understood. “With that approach, I know I can always make a difference”.
How to Win in the Court of Law
In court, three things are critical: (1) Preparation, you can’t be overprepared in your familiarity with the evidence and law. (2) “Reading the room”. Learning when to abandon a strategy that you were invested in because it isn’t serving your client, and to adopt a new one on your feet, because things can change dramatically on the road to court and in court. (3) Having a cool head is an obligation you have to your client and the court. You don’t want to have been distracted or deterred by your opponent’s cheap tactics: “I am not willing to use them, but I have experienced several playbooks’ worth of those”.
The tribunal is usually where all the facts are found (not on appeal), and so it is essential to ensure your client has put forward all the evidence they can, you have scoured it, asked them for more if needed, and that it is supported by witnesses of fact and expert witnesses if necessary. On the flipside, an effective cross-examination in the tribunal may be key to winning your case. Recently, in Moran v HMRC [2025] UKFTT 540, Rebecca was sole counsel for HMRC in a case with seven witnesses and several complex arguments of law.
Rebecca recalls, “I had to discredit the evidence of all of the witnesses in order to win the case. One point of law (“the Motive defence” to the transfers of assets abroad provisions) turned on the Appellant proving that her deceased ex-husband did not set up an offshore trust structure for tax purposes. She relied on a loyal colleague of his from the 1990s (“SD”), stating that he did not take legal advice at the time. She had written a clear, concise statement to that effect, referring to some details of the structure, and I had prepared a very careful cross-examination for her. But as I listened to her interacting with the judge as she was being sworn in, my instincts told me that she could not even understand what was in her statement. I abandoned my plan. Instead, I took her to a paragraph of her statement on the trust structure and asked her whether she had heard of “Namib” (a company owned by the trustees she mentioned). She replied “no”. I asked if she had written the statement herself. She replied in outraged astonishment, “Yeah, why’d you ask that?”. I replied, “Well, you have written this very precise paragraph about the trust structure, but I have just asked you about it, and you don’t seem to know anything about it”. SD then admitted she knew nothing at all about the structure and did not recall anything from that time, including whether or not tax advice was taken”.
That is also an example of how it’s necessary to make judgment calls as the case progresses, whatever stage of appeal you are at. In the UT and CA, things move at such a pace that you have to adapt instantly to a tack taken by the judge(s), explains Rebecca.
Victory After Victory
She recalls another case. “Recently in the UT in Trachtenburg v HMRC, a point of law with far reaching consequences (whether HMRC had any power to assess the pension scheme unauthorized payment charge and scheme sanction charge), the judge said to me after I stood up and said good morning: “We have digested your skeleton argument, we only want to hear from you on any further points”. That has never happened to me before. There were two explanations in my mind: (1) My skeleton was so clear it had done the job, (2) the opposite of that! I took the cautious view that it was the opposite of that. I quickly decided on the simplest way of cutting through all my opponents’ points to ensure that my arguments had been understood and made my submissions”.
In her written advocacy, Rebecca uses short sentences and treats a statutory analysis like an equation and only cites the principle of the cases she relies on, not lengthy passages. Where there is much detailed evidence, the best way of making sure it lands with the judge is an evidence note. She did this in Beresford, where the question was whether a serviced office activity was wholly or mainly an investment business for the purposes of business property relief from inheritance tax. The Appellant was trying to detract from the facts and sail above them, in general principles and analogies. Rebecca made oral submissions on their contentions on the general principles, undermining them with case law, and then prepared an evidence note on the detailed facts in order to win the case for HMRC.
Similarly, in Bell & others v HMRC, the case turned on the expert evidence by HMRC’s valuer of shares which had been gifted to charity. Rebecca knew there was too much detail for oral submissions, and so she made those at a high level, and proposed an evidence note, which was materially adopted by the judge in his decision for HMRC. She ensures that she utilizes her team effectively, establishing proper communication channels and obtaining their input throughout. “I am lucky to work with specialists across all the taxes, and I always value their contribution”.
Rebecca has spent much time advising in the Private Client and Private Equity arenas in many different contexts, in planning and disputes. She is involved earlier in discussions with HMRC by taxpayers nowadays, as it’s recognized that she can spot helpful arguments and see things differently when clients have been at loggerheads for some time. Many of her clients reach a happy outcome before litigation. “Whether or not that is the case, it brings me joy to turn things around for people when a lot is riding on it for them”.
The Triumph She is Proud of the Most
Finally, she highlights a particular legal argument that she is most proud of and the broader impact of that outcome. “There was a moment in the Supreme Court in Eclipse Film Partners (No 35) LLP v HMRC, where a paragraph in my written pleadings made them refuse the other side permission to appeal at oral hearing”.
“I was led in that case as it was worth £2BN of itself and was related to a film scheme which had been done by other promoters as well, so the value was estimated to be much higher than that. We were acting for HMRC from the FTT onwards. I drafted the pleadings at each stage”.
“There was a particularly important paragraph of our written case which I had drafted which responded to case law that our opponents were relying on to show that the legal principles in relation to the question whether a person was trading was in disarray”.
Rebecca’s leader’s view was that they shouldn’t respond to any of these cases at all because it was very obvious that the question of trade was mainly one of fact, and the test was already clear in the lead authority, Ransom and Higgs.
“We had a debate within the team as to whether we should include this paragraph, and in the end we settled on me reducing it to a page, with a bullet point for each case to say what the case was about and why as a matter of fact in those cases the appellant was found not to be trading and what the test was”.
“In the event, that paragraph was put by the Supreme Court (Lord Neuberger) to our opponents in their oral submissions seeking permission and was the reason that they were refused permission to appeal, because their only hope of getting permission was to demonstrate there was an uncertain point of law of public importance, and they failed to do that with the cases they relied on because we demonstrated in this one paragraph that the cases simply applied the same principle in Ransom v Higgs, which was perfectly clear”.
As a result of that, the Court of Appeal decision stands as the authority on the question of ‘trade’ and is a landmark decision in film schemes”.
Flying High in the Upper Echelons
At Devereux Chambers, Rebecca practices in all areas of tax, litigation, and advice. That’s why she considers the most significant recent developments and trends in UK tax law necessary to be adapted to in her practice. “As a result of the Autumn Budget, I have been involved in a lot more restructuring work for previously ‘non-domiciled’ individuals and private equity investors. I have an extremely varied practice, I have also been advising different Crown departments on very high value national structures and projects, advising across all direct and indirect taxes”.
In addition, she has been asked to assist in drafting legislation and informed of policy when instructed by the Government departments, including on litigation.
When asked about what role she believes tax barristers play in shaping public policy and ensuring fairness within the UK tax system, Rebecca says that she is lucky to be instructed on high-value complex cases, now on the Attorney General’s A-Panel of Counsel, and she is against silks nearly always. “It means I am influencing the development of the law and policy, it is challenging and rewarding”.
Trusting Her Instincts, Always!
As a barrister, Rebecca firmly believes ‘You have to have your own moral compass and trust your own instincts’.
When asked about her approach to mentorship and what advice she would offer to aspiring tax lawyers who are just beginning their careers, Rebecca says that she has been told all the time that her LinkedIn posts and articles both teach and inspire, “And so it’s important to me that I do those”. She also does a lot of technical talks and other articles that have the same function.
Within Chambers, she has a vast amount of technical knowledge and experience, and so she is frequently asked by juniors for her input into their work. She usually takes them through the legislation and discusses points with them.
Rebecca very much made her own way at the Bar, guided by instinct, and so she provides guidance to juniors on how to do that as well. “The bottom line is that this career is a calling; if you don’t know that you belong here, then it is not for you”.
The Equilibrium of Efficiency
In balancing the varied demands of her legal practice with the need for personal and professional growth, Rebecca learned through many different types of experiences, personal and professional, that what appears to be ‘going on’ in your work environment and your life is in fact a reflection of what you are experiencing on the inside. “If things seem stressful or upsetting, I question what it is that is really making me feel that way, and I deal with that issue, because usually it isn’t the thing that just happened. We are all a product of our experiences and how we choose to handle them”. She likes to start the day feeling good and make choices that keep it that way.
When asked what role she sees technology playing in the future of tax law and legal practice, Rebecca pauses for a moment. “This is a tricky one as it feels like AI is improving at such a rate and rapidly becoming part of every lawyer’s day, it is hard to know”.
She says she can still do a better legal analysis than AI at least: “I ask it questions I know the answer to and at the moment I am not concerned about it wiping out the good barristers, it gets things badly wrong, often giving the opposite answer to a question whether something is subject to tax”.
Envisioning Ahead
When probed about how she envisions the UK tax system evolving over the next decade, and what challenges and opportunities this presents for legal professionals, Rebecca believes that it is certainly getting more complex every year, and there is a lot more litigation. Her practice is getting busier all the time; she doesn’t see the positives for the economy from that, though.
The Autumn Budget in 2024 caused thousands of multi-millionaires to leave the UK and will result in lost tax and an even bigger deficit. “If you ask any accountancy or solicitors firm with a Private Client practice, they will tell you that an alarming number of their wealthiest clients have left the UK”. The Government is denying this at the moment. It can’t be seen in payroll statistics because these individuals are not employees, they are investors, shareholders, asset managers etc. so the results showing how much the UK economy has lost in tax rather than raised, won’t be available to prove what their changes to the law have done to revenue until tax returns for 2025/26 are filed in January 2027. “I don’t see that it can be fixed as these individuals have already made a life elsewhere, feeling like the UK does not want them”. The Government seems set on making even more bad decisions, which will drive even more individuals away. It is difficult to see how on earth they could turn this around to grow the economy, and it is compounded by their decisions in relation to Agricultural and Business Property Reliefs, feels Rebecca in her gut.
Creating a Legacy
Finally, when asked what legacy she hopes to leave as a tax barrister and how she wants to be remembered by her peers and clients, Rebecca says, “I would like to see equality in my lifetime and a profession in which bullying and harassment are not part of the culture”. It irritates her when people cite the fact that there are now more female pupils than male ones being taken on at the Bar, because it is nothing to the point. At the moment, the rate at which the Bar loses women in their 30s would mean there would have to be 75% women at the pupillage stage, and then in twenty-five years, there might possibly be equality (although it may just mean more women leave…). There are examples of women at the Bar with children, “But I always felt it was one or the other, both weren’t possible”. That is a large part of the reason women in the past few decades have simply left the Bar, and we have under 20% female silks. There has been an inbuilt prejudice against women; the Bar is inherently hierarchical, patriarchal, and misogynistic. This is not solved by the senior males having more female juniors, which plays to the stereotypes. In a client market that is not accountable at all for which barristers they instruct and why, and barristers are only concerned with competing against each other to get work and win cases, all kinds of prejudice take place.
Ensuring Tomorrow Turns Out Better Than Yesterday
“So, I would like to see two things. (1) Our regulator, the Bar Standards Board, works with the other professional regulators for those instructing us, the Solicitors Regulatory Authority and the Chartered Institute of Tax, the ICAEW, etc., to develop a system so that a number of advocates are at least considered for cases and advisory work. That would go a long way to making the market think about why they are instructing particular counsel and be accountable for those decisions. (2) A drastic improvement in the way that complaints for sexual harassment and bullying at the Bar are dealt with by the regulator. Rebecca Murray has spoken about that a lot, both to the regulator and publicly in the past few years, and a consultation is underway to change the rules.
Once that happens, Rebecca will surely feel a tiny part of her legacy coming true.
The team of ‘The Euro Leaders magazine’ thanks ‘Rebecca Murray, Tax Barrister at Devereux Chambers,’ for such a detailed discussion and wishes her the very best in her future endeavours.