Stephen Morse

Stephen Morse has over twenty five years’ experience in tax. He joined Temple Tax Chambers in April 2025 following the successful completion of his pupillage. Before joining Chambers, Stephen was a tax and legal partner at PwC where he specialised in contentious tax, dispute resolution and tax litigation.

Stephen accepts instructions in all areas of Chambers’ expertise from Solicitors, Accountants, Tax Advisers and other professionals under Licensed Access. He will be accepting instructions in appropriate cases from members of the public and intermediaries under the Public Access Scheme from 16 June 2025.

From September 2025 Stephen will be a visiting lecturer in taxation law at the Dickson Poon School of Law, King’s College London, where he will be teaching Indirect Taxation to postgraduate LLM tax students.  

Recent instructions

During pupillage and now as a tenant, Stephen has worked on a wide range of contentious and advisory matters. He has been extensively involved in litigation and dispute resolution as pupil and now as counsel in the First-tier Tribunal, the Upper Tribunal and the Court of Appeal, as well as judicial review in the Administrative Court, in Magistrates’ Court proceedings relating to excise duty and in the County Court in proceedings related to an Employee Benefit Trust arrangement.

Direct taxation

Confidential client v HMRC (five day hearing in the FTT, decision awaited): interpretation of closure notices, application of the PAYE regime, establishing a UK presence for tax purposes, application of the agency rules, application of contract law and estoppel to tax appeals involving allegations of tax avoidance. Junior to Ximena Montes Manzano

Confidential client v HMRC (two day judicial review in the Administrative Court, decision awaited): challenge to HMRC’s decision-making process concerning the application of s. 689(7A) ITEPA 2003 (employees of non-UK employers). Junior to Ximena Montes Manzano

Confidential client v HMRC: ADR proceedings concerning assessments to ‘deliberate’ penalties and to ‘offshore asset-based’ penalties related to a substantial capital gain. This involves complex matters of domestic and German law on employment status, company law and corporate governance

FRF (South Wales) Ltd v HMRC [2024] UKFTT 1145 (TC): The FTT had to decide the proper statutory meaning of the words ‘conversion’ and ‘renovation’ in the Capital Allowances Act 2001, and find as a fact whether or not the substantial alterations to the structure and the fabric of the building amounted to a ‘conversion’

Confidential client: acting for a FTSE 100 client in an international tax dispute concerning the proper application of the relevant EU and domestic law involving questions of corporate purpose and the application of anti-abuse provisions

Confidential client v HMRC: challenging HMRC’s rejection of a substantial Research and Development (R&D) tax relief claim. This matter involves detailed analysis of complex engineering and scientific evidence addressing sensitive R&D projects in the defence industry

Confidential client v HMRC: an appeal against a Schedule 36 information notice in the context of a complex international corporate group structure and the proper application of OECD / domestic transfer pricing rules. Junior to Keith Gordon

Delphi Derivatives v HMRC [2023] UKFTT 722 (TC): appeal to the Upper Tribunal on the application of ‘deliberate’ and ‘careless’ penalty regimes to complex historic facts

Brian Lynch v HMRC [2025] UKFTT 300 (TC): appeal to the Upper Tribunal addressing the application of the Ramsay principle to historic facts including whether or not a series of transactions can be aggregated to create a ‘dry tax charge’. Junior to Keith Gordon

Confidential client v offshore trustees: County Court proceedings relating to the termination of an Employee Benefit Trust arrangement

Indirect taxation

HMRC v Innovative Bites [2025] EWCA Civ 293: junior counsel (to Tim Brown) in the Court of Appeal dealing with the zero-rating VAT regime for food products. The appeal involved the principles of statutory interpretation and the precise scope of findings of fact in the FTT

FS Commercial v HMRC [2025] UKUT 13 (TCC): junior counsel (to Tim Brown) in the onward appeal to the Court of Appeal, having successfully sought permission from the Upper Tribunal. This appeal will address important issues relating to a taxpayer’s entitlement to input VAT recovery, and the basis upon which a taxpayer may exercise their right to recovery.

Confidential client v HMRC: complex proceedings before the FTT involving the proper scope of the financial services / insurance VAT exemption, Zipvit-type principles relevant to claims for ‘embedded VAT’ and the scope of the FTT’s powers on various case management matters including the power to strike out proceedings / debar HMRC

Confidential client v HMRC: an application to the FTT to debar HMRC from an appeal against HMRC’s decision to impose ‘deliberate’ VAT and ‘civil evasion’ excise duty penalties, on the basis that HMRC’s case has no reasonable prospect of success. This matter involves wider legal questions relating to the burden and standard of proof, the law relating to allegations of ‘dishonesty’ and the application of ‘deliberate’ and ‘civil evasion’ penalties to companies

Procurement International Limited v HMRC [2024] UKFTT 949 (TC): whether a taxpayer was entitled to apply VAT zero-rating to goods sold and transported to a third party outside of the UK, and thus within the scope of zero-rating for exports – appeal allowed

Confidential client v HMRC: proceedings in the Magistrates’ Court relating to the proper application of the seizure and restoration excise duty regimes relating to the alleged improper use of ‘red diesel’ in commercial operations. The case will decide important principles relating to the proper scope of the continuing excise duty relief for ‘forestry’

Advice relating to the application of VAT to private schools, including partial exemption / VAT recovery, the application of tax point rules to fees in advance / fee pre-payments, the application of the capital goods scheme and related compliance matters

Advice relating to the application of the zero-rating reliefs for aids to the disabled, relating to an innovative product recently into the market

Advice relating to the application of zero-rating to new food products

Missing trader / MTIC appeals and advisory matters (pupil / junior to Tim Brown and Michael Avient)

Other Experience

In his previous role Stephen acted for various large multi-national clients, corporates, private equity houses and some private clients on a range of direct tax, indirect tax and transfer pricing matters.

These included:

• advisory, structuring and compliance projects
• complex and high-value tax investigations in the UK and overseas
• various formal and informal alternative dispute resolution (ADR) processes

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