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MA (Oxon) LLM (Cantab)
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Peter has a breadth and depth of experience and expertise in the field of VAT unsurpassed at the junior bar.
He is regularly instructed by accountants and solicitors to advise clients, in many sectors, on VAT issues which they need to resolve. Peter has helped private clients successfully address a wide range of VAT issues, from Assessments to Zero-rating. “He is always prepared to go the extra mile and impresses clients with his technical understanding and knowledge of the law” (Chambers UK). If disputes with HMRC do require an appeal to be made to the specialist tax tribunal, Peter is “a pleasure to have representing you; he’s professional but at the same time makes the client feel included within the litigation, never over-complicating matters” (Chambers UK). He has recently acted for clients in the charities, education, e-commerce, insurance and financial services sectors, amongst others. Peter has extensive experience acting for, as well as against, HMRC and is regularly entrusted by HMRC with advice and litigation in complex high value cases.
Peter has appeared in over 100 reported VAT cases (major cases reported in Simon’s Tax Cases, which were decided by the Upper Tribunal or by the higher courts), including successful appearances in the Court of Appeal and the Supreme Court. This is in addition to frequently representing clients in appeals to the First-tier tax Tribunal, where most tax litigation is resolved. Before EU Exit he regularly represented the UK in the European Court of Justice in VAT cases. His strong reputation on points of EU law helps equip him well to handle disputes over retained/assimilated EU law, as it continues to affect UK taxpayers, and over post-EU Exit amendments to the UK’s VAT legislation.
Peter was part of the HMRC counsel team which won the Littlewoods multi-billion pound compound interest litigation in the Supreme Court (in 2017), the only counsel to represent HMRC in every court throughout that litigation. He acted in the first VAT Group Litigation to be tried in the High Court.
Peter brings skills originally acquired across a broad range of civil litigation and honed in the tax field, including valuable insights gained from representing both private clients and HMRC.
His tax practice includes tax judicial reviews and human rights based claims.
Alongside VAT, his practice includes excise duty and other indirect taxes.
Selected major cases
Three groundbreaking VAT cases
Other major cases
Peter is frequently instructed in tax litigation. He also advises clients on solutions to a variety of indirect tax issues and in connection with disputes with HMRC.
Peter initially made his name by representing HMRC and still regularly appears for them as a government A panelist. He was counsel to HMRC in the first VAT Group Litigation.
Peter now regularly receives instructions on behalf of taxpayers, both to advise and in relation to disputes, including from top 10 accountancy firms. He is often instructed to appear against the leading VAT silks achieving a number of notable victories. He recently won for City YMCA in the FTT successfully defeating an array of arguments advanced on behalf of HMRC. HMRC did not seek permission to appeal.
Peter has worked for his clients on a variety of areas, including on assessments, consideration and taxable amount, exemptions, input tax deduction and partial exemption, single/multiple supplies, claims for overpaid tax (including time-limits, unjust enrichment and interest), outside the scope activities, penalties, place of supply, registration, security requirements, unfair treatment of taxpayers, and zero-rating.
He has advised and handled disputes in cases across sectors such as charities, construction, education, energy, health, insurance, financial services, food, land and property, health care, labour providers, publishing, retailing, transport, travel agents and holidays, telecommunications and internet services, welfare services. Alongside such mainstream areas, Peter has recently added advice concerning canals and litigation concerning yachts.
He is often instructed in matters involving new or difficult points of law, arising out of retained /assimilated EU law including the EU VAT Directives or construction of UK legislation. He also has acumen advising on more everyday situations and problems.
He regularly represents clients in VAT cases in the specialist tax tribunal, where he brings to bear great his specialist experience and expertise, and skills cross-examining witnesses initially developed outside the tax area across a wide range of civil litigation. He is experienced in litigation involving questions of fact requiring the ability to handle extensive evidence (documents and witnesses).
Peter is a regular advocate in cases which require further appeals to the Upper Tribunal and Court of Appeal, often in high value, legally complex cases.
In addition Peter often represents clients in judicial reviews involving HMRC, including equal treatment cases and human rights cases. Civil actions against HMRC in the High Court, and some criminal defence work involving VAT, have also featured in Peter’s practice.
Peter has experience in excise cases (including a 10 day excise hearing before the First-tier Tribunal, representing a duty guarantor). He has advised on Insurance Premium Tax and appeared in IPT appeals. He has also dealt with stamp duty/SDRT.
Peter has experience advising on consumer credit and related legislation and representing clients in civil actions and in some criminal proceedings under the 1974 Act.
He has acted for major lenders, including HSBC and Nationwide, as well as a variety of smaller lenders and traders involved in consumer credit transactions. He has given advice in relation to terms of regulated agreements, including hire purchase, conditional sale and running account credit agreements, licensing (including representations to the OFT), advertising and quotations.
In 2013 he represented the OFT in a major consumer credit licence revocation and money laundering penalty case involving payday lending (MCO Capital Ltd v OFT CCA/2012/0015).
Peter has appeared and advised in a number of human rights cases, particularly, but not exclusively, in the indirect tax field.
His experience includes issues in relation to “retrospective” time limits, alleged infringements of the right to property, requirements to pay tax demands before tribunal proceedings can be commenced, and matters relating to the right to a fair hearing, including standovers pending criminal proceedings and the initial challenges to the independence of VAT & Duties tribunal under Article 6.
A number of cases outside the tax area include matters involving the protection of family businesses from local authority action.
Tax: Indirect Tax: Band 1 Junior: “He is always prepared to go the extra mile and impresses clients with his technical understanding and knowledge of the law.” “I am always confident that Peter has the measure of the arguments put forward by opposition tax counsel and is not deterred by adverse events.” “A pleasure to have representing you; he’s professional but at the same time makes the client feel included within the litigation, never over-complicating matters.” – Chambers UK, 2023
Tier 1 junior in Tax: VAT and excise – Legal 500, 2023
Tax: Indirect Tax: “Peter Mantle continues to impress with his deep knowledge of indirect taxes. He knows reams of stuff and is very good on the technical points” – Chambers UK, 2022
Leading junior in Tax: Corporate and VAT: ‘‘Peter can be relied upon to give a fully balanced appraisal of the position, avoiding either hedging all his views or being excessively optimistic. As he is instructed by both HMRC and tax payers, he can see the position from both sides and is a good guide to HMRC’s probable attitudes and thought processes. His opinions are detailed and logical.’’ – Legal 500, 2022
Tax: Indirect Tax: “He is very methodical and measured.” “Peter displays precisely the right mix of tax technicality and commercial acumen required. He always enables clients to understand the intricacies of VAT law.” – Chambers UK, 2021
Leading junior in Tax: Corporate and VAT: ‘‘He is able to explain complex ideas in a straightforward way that clients like. He is also willing to adopt challenging arguments if he believes in the cause.’’ – Legal 500, 2021
Tax: Indirect Tax: “Excellent and extremely well prepared.” “He is clear in his advice and strong technically.” – Chambers UK, 2020
Leading junior in Tax: Corporate and VAT: ‘‘He is willing to bring new ideas and solutions to the table.’’ – Legal 500, 2020
Tax: Indirect Tax: “He absorbs information like a sponge and is able to deliver the most intellectually demanding ideas with the utmost clarity in court.” “He dispenses both technical expertise and practical industry knowledge in a thorough and logical manner.” – Chambers UK, 2019
Leading junior in Tax: Corporate and VAT: ‘‘Helpful and technically very sound.’’ – Legal 500, 2018
Tax: Indirect Tax: “He provides balanced, thorough and insightful advice that focuses on how to win the argument.” “His preparation is excellent and he is very clear in conference.” – Chambers UK, 2018
Leading junior in Tax: Corporate and VAT: ‘‘Strategically excellent; he’s able to quickly identify the chinks in an opponent’s arguments.’’ – Legal 500, 2017
Tax: Indirect Tax: “For representing HMRC he’s the best of the best of juniors.” “Incredibly hard working and very reliable.”– Chambers UK, 2017
Member of the A Panel of the Attorney General’s panel of counsel, first appointed 2005
Contributor of articles to the Tax Journal and past contributor to De Voil’s Indirect Tax Intelligence
VAT Practitioners Group
Revenue Bar Association