Ximena Montes Manzano

Ximena was called to the Bar in 2004, successfully completed a pupillage in a prestigious public law set of Chambers and started practising tax law in 2007.

Ximena accepts instructions in all areas of Chambers expertise from Solicitors, Accountants, Tax Advisers and other professionals under Licensed Access.

Ximena is qualified to take direct instructions from members of the public and intermediaries under the Direct Access Scheme in appropriate cases.

Tax and Revenue Law

Ximena is a highly-regarded tax litigator. She has wide experience of group litigation and appears for taxpayers only in multi-day proceedings in the tax tribunals and higher courts (including Judicial Review challenges against HMRC). Her client list features corporates, partnerships, owner-managed businesses, media personalities and HNW individuals.

Recent successes include defending taxpayers who participated in historical EBT/ contractor loan arrangements against unreasonable and disproportionate information notices and substantial penalties for alleged carelessly/ deliberately inaccurate returns.

Ximena also has conduct of a number of high-profile IR35 appeals, appeared as junior counsel for Atholl House Productions Ltd (Kaye Adams) in the Court of Appeal and in the successful remittal of the case to the First-tier Tribunal.

In addition to litigation, Ximena advises clients on a variety of matters, both before and after filing their tax returns. Her advice includes planning, strategy, alternative dispute resolution, formal complaints and actions for damages for professional liability.

Recent Cases

Supreme Court

-Hancock v HMRC [2019] All ER 473 (whether s. 116 TCGA applies on a single transaction converting QCBs and non-QCBs into QCBs)
-HMRC v Cotter [2014] 1 All ER 1 (what is information included in a tax return – carry back of losses)

Court of Appeal
-HMRC v Atholl House Productions Ltd [2022] 4 All ER 461 (IR35 – the scope and meaning of being in business on own account RE Kaye Adam's services to the BBC)
-Beadle v HMRC [2020] 1 WLR 3028 (Challenge to the validity of an APN as part of an appeal against a penalty for failure to comply with said APN)
-R (oao City Shoes Ltd and Ors) v HMRC [2018] EWCA Civ 315 (Judicial Review challenge of unannounced change of policy re Lichtenstein Disclosure Facility)
-Sanderson v HMRC [2016] 3 All ER 203 (Discovery assessments)
-Daniel v HMRC [2013] STC 744 (Residence and IR20)
-R (oao Bampton Property Group Ltd) v King & HMRC [2014] STC 56 (Judicial Review challenge of HMRC’s SP5/01 guidance on CT loss relief claims)

High Court

-R (on the application of White & Laws) v HMRC [2025] EWHC 1600 (permission to apply for judicial review involving a group of 46 claimants challenging HMRC’s use of the s.684(7A) ITEPA discretionary power to deny PAYE credits in offshore contractor loan schemes)
-R (oao Broomfield & Others) v HMRC [2019 1 WLR 1353 (Judicial Review challenge of APNs and Follower Notices)
-London Borough of Haringey v Goremsandu [2013] EWHC 3834 (Admin).
-Garlick v Secretary of State for Communities and Local Government [2013] EWHC 1126 (Admin). (Judicial Review)
-Gripple Ltd v HMRC [2010] STC 2283 (R&D reliefs)
-R (oao Grimsby Institute of Further and Higher Education) v Chief Executive of Skills Funding (formerly Learning and Skills Council) [2010] EWHC 2134 (Admin); [2010] 3 EGLR 125. (Judicial Review)
-R (oao Parissis) v Grinyer (Inspector of Taxes) [2010] STC 891. (Judicial Review of Information Notices)
-R (oao London Borough of Barnet) v Parking Adjudicator & Moses [2006] EWHC 2357 (Admin). (Judicial Review of Parking Enforcement Notices)

Upper Tribunal

- Delphi Derivatives Limited (In Members’ Voluntary Liquidation) v HMRC [2026] UKUT 21 (TCC) (penalties for careless/deliberate inaccuracy, causation, agency and fairness of proceedings)

- Red, White and Green v HMRC [2023] STC 773 (IR35 and application of Ready Mixed Concrete third test to Eamonn Holme’s services to ITV)
- Harrison v HMRC [2022] UKUT 216 (TCC) (Penalties for late submission of tax return and withholding information)

-HMRC v Inverclyde Property Renovation LLP & Clackmannanshire Regeneration LLP [2020] STC 1348 (LLPs and correct enquiry procedure)
-HMRC v Bosher [2014] STC 617. (Penalties and proportionality)
-HMRC v Pawson (Deceased) [2013] STC 976. (Business Property Relief)
-HMRC v Charlton [2013] STC 866. (Discovery assessments)
-Wrag Barn Golf and Country Club v HMRC [2012] STC 1572. (VAT exemption)
-Tuczka v HMRC [2011] STC 1438. (Residence and Ordinary Residence)
-Grimsby College Enterprises Ltd v HMRC [2010] STC 2009. (VAT exemptions)

First-tier Tribunal

- Atholl House and HMRC - [2024] UKFTT 37 (TC) - (IR35 - remitted hearing from the Court of Appeal)

- Kenan Altunis and HMRC [2023] UKFTT 719 (TC) (Penalty for alleged deliberate/ careless conduct in participating in a failed tax avoidance scheme)

-Whispering Smith Limited v HMRC [2022] UKFTT 00165 (TC) (Follower Notice penalty)

-Yerou v HMRC [2022] UKFTT 00079 (TC) (relationship between Information Notices and Discovery Assessments)
-Avonside Roofing Limited v HMRC [2021] UKFTT 0158 (TC) (Information Notice on EBT case)
-Portview Fit-Out Limited v HMRC [2021] UKFTT 0447 (TC) (Penalties on EBT case)
-Andrew White v HMRC [2019] UKFTT 0659 (TC) (Main Residence Relief)
-Derek and Susan Smallman v HMRC [2018] UKFTT 0608 (TC) (SDLT repayment claim)
-Benton and Others v HMRC [2018] UKFTT 0593 (TC) (Follower Notice Penalties)
-Benton and Others v HMRC [2018] UKFTT 0594 (TC) (Objection to HMRC’s Recusal Application)
-Beneficial House (Birmingham) Regeneration LLP & Stanley Dock (All Suite) Regeneration LLP v HMRC [2017] UKFTT 0801 (TC) (Closure Notice Application)
-Benton and Others v HMRC [2017] UKFTT 0396 (TC) (Strike out Application)
-Ross (Deceased) v HMRC [2017] UKFTT 0507 (TC) (Business Property Relief)
-Nichols & Anor v HMRC [2016] UKFTT 155 (TC) (Closure Notice Application)
-Barrett v HMRC [2015] UKFTT 0329 (TC) (Penalties - Reasonable excuse)
-Prince and others v HMRC [2012] UKFTT 157 (TC) (P800 is not appealable decision - appointed as Amicus Curiae by the President of the First-tier Tribunal.
-Scofield v HMRC [2011] UKFTT 199 (TC) (CIS withdrawal of gross payment status and FTT’s jurisdiction) and costs application [2012] UKFTT 673 (TC).
-Grace v HMRC [2011] UKFTT 36 (TC) (Residence)

Education, Professional Memberships and Appointments

• BSc (Town and Country Planning) - University College London - 2003
• Post Graduate Diploma in Law - The College of Law, London - 2003
• Bar Vocational Course - The College of Law, London - 2004
• Call to the Bar - Middle Temple - 2004
• Registered member of Advocate (Bar Pro Bono Unit)
• Member of the Administrative Law Bar Association
• Member of the Revenue Bar Association
• Member of the Bar Council's Direct Access Panel 

Publications

Ximena is the author of four editions of Main Residence Relief (Claritax) and an author in Taxation, Tax Adviser and Personal Tax Planning Review journals.
 
Ximena is also co-author of Disguised Remuneration and the Loan Charge (Claritax) second edition due to be published in early 2026.

Ximena won the Rising Star category in the 2014 Lexis Nexis Taxation Awards. 

Directories - Professional Recommendations

'Ximena is very approachable and responsive. She cuts to the heart of the matter and provides clear and pragmatic advice to clients. She is very thorough in her preparation and is a calm and effective advocate.' - Legal500 2025 (Ranked Tier: 2)

"Ximena has great technical skills and her bedside manner is fabulous. She never gets flustered." - Chambers and Partners 2024 (Ranked Band 3)

"Ximena is a strong advocate who prepares thoroughly.’" Legal500 2024 (Ranked Tier: 2)

"A calm and assured advocate, Ximena understands how to present evidence in a clear and concise way and makes sure that she works closely with the client so that they have confidence in her advice and strategy." "Ximena is an incredibly hard-working barrister who manages to combine huge technical knowledge with practical solutions."- Chambers UK 2023 (Ranked: Band 3)

"Ximena Montes Manzano is a well-respected junior known for her work representing clients at all levels of the court system. She regularly counsels clients on corporate tax issues as well as professional conduct cases." - Legal500 2023 (Ranked: Tier 2)

"She is able to unpack complicated and fact heavy disputes and get to the heart of the matter quickly. Her approach has the right balance of empathy and grit that makes client feel taken care of. " - Legal 500 2022 (Ranked: Tier 2)

"She is very approachable and identifies the issues immediately and then prepares a fully considered response." - Legal 500 2021 (Ranked: Tier 2)

"She has a fierce intellect with an astonishing capacity to assimilate all of the relevant facts from extensive bundles of documents'' - Legal 500 2020 (Ranked: Tier 2)

"She is an extremely useful advocate in contentious tax cases" - Legal 500 2018 (Ranked: Tier 2)

"Readily walks the client through every stage of complex tax cases" - Legal 500 2017

"Fiercely bright and tenacious with excellent commercial judgement" - Legal 500 2016 

What clients say about Ximena:
"We are very happy with Ximena's high standard of work"
"I could not have done it [the case] without her"
"She is very helpful and accommodating"
"She works incredibly hard"
"I am pleased to see someone doing so well at the junior Bar. Cross-examination was effective and on point" - Judicial comment

Additional Information

Languages

Native Spanish.
 
Interests
Fitness, travelling, scuba diving and dancing.
 
Privacy Notice

Please click here for Ximena Montes Manzano's Privacy Notice.

View All Members >