Michael Avient

Michael Avient has 30-years of experience in tax.  In his previous role as a partner, he has led the London tax investigation teams at a number of top 20 accountancy firms.  During this time, Michael was responsible for litigation policy and strategy and was instructed in leading cases including R (oao Derry) v HMRC [2019] UKSC 19 and R (oao De Silva and another) v HMRC [2017] UKSC 74.  His success in this area led to his team winning awards twice at the Taxation Awards.

Michael is also an acknowledged expert on tax avoidance and has written extensively on the issue in professional journals.  He is also asked regularly to give expert evidence on the subject.

Michael accepts instructions in all areas of Chambers expertise from Solicitors, Accountants and Tax Advisers.

Recent Instructions

-          Advice and appearance in Bankruptcy Court

-          Advice on capital gains exemptions

-          Advice on VAT in relation to licences

-          Advice on VAT in relation to overseas supplies and supply of intermediary services

-          Appeal to FTT in relation to existence of a trade with a view to profit

-          Appeal to FTT in relation to securities transactions

-          Advice and appeal to FTT in relation to trade losses

-          Advice in relation to a film LLP

-          Advice and appearance in Social Security Tribunal

-          Appeal to FTT in relation to film rights trading

-          Junior in relation to a share loss appeal to FTT

Education, Professional Memberships and Appointments

LLB (Law) Cardiff University

Master of Laws (LLM) Southbank University

Association of Tax Technicians

Directories - Professional Recommendations

‘He has an excellent legal mind and in addition has a superlative grasp of procedure, which he has employed to good effect in a number of litigation skirmishes with HMRC. He is also a very strong advocate.’ - Legal500 2025

"Michael's strengths are his honesty, persistence and work ethic in analysing the case before him in depth and objectively, but always with the interests of his client as the priority." - Legal500 2024

"Michael has a good knowledge and in-depth nuanced understanding of how to deal with HMRC and accessibility and dependability." - Legal 500 2023

Recent Cases

• Mr Declan Durey v (1) South Central Ambulance Service NHS Foundation Trust (2) Protect (Intervenor) 3316004/2019 & 3328242/2019
• Ives v Revenue And Customs (Closure notices referring to omitted "property developing income" - whether the "matter in question") [2023] UKFTT 968 (TC) (13 November 2023)

• Bhaur & Ors v Equity First Trustees (Nevis) Ltd & Ors [2023] EWCA Civ 534 (18 May 2023)
• OMOLADE NETUFO v Revenue & Customs (Restoration of seized goods - on grounds that small brewery relief claimed inappropriately on imported beer and that the Appellant was carrying out wholesale sale of alcohol without requisite approval) [2023] UKFTT 121 (TC) (10 February 2023) 
• DAVID OAKES v Revenue & Customs (INCOME TAX AND VAT - application to bring late appeals - whether notices sent or received - reliance on agent) [2022] UKFTT 413 (TC) (10 November 2022) 
• MR KEVIN JOHN PITT v Revenue & Customs (TAX AVOIDANCE - income tax - whether or not a loss arose under paragraph 2 of Schedule 13 to the Finance Act 1996 on the acquisition and disposal of relevant discounted securities) [2022] UKFTT 222 (TC) (19 July 2022)
• Whyte v Revenue & Customs (INCOME TAX AND CAPITAL GAINS TAX - sale of serviced building plots in grounds of Grade I listed building - sale proceeds used for restoration of listed building) [2021] UKFTT 270 (TC) (26 July 2021) 
• Gearslutz.com Ltd & Anor v Revenue and Customs (Application for Closure Notices) [2021] UKFTT 150 (TC) (11 May 2021) 
• Revenue & Customs v Premiere Picture Ltd (NCOME TAX, CAPITAL GAINS TAX AND CORPORATION TAX - disclosure of tax avoidance schemes) [2021] UKFTT 58 (TC) (09 March 2021) 
• Cartref Care Home Ltd & Ors, R (on the application of) v HM Revenue and Customs [2020] EWCA Civ 1744 (18 December 2020) 
• Mashoof v Revenue & Customs (STAMP DUTY LAND TAX - paragraph 25 of schedule 10 to Finance Act 2003 - whether Revenue determination made, issued and served) (Rev 1) [2020] UKFTT 166 (TC) (25 March 2020) 

Publications

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