I am a fourth seat trainee in HM Revenue & Customs (HMRC) Legal Group’s European and International Law advisory team. The team advises on, drafts and helps negotiate a range of international agreements, including Free-Trade Agreements and Double Taxation Treaties.

I studied Philosophy and Politics as my undergraduate degree, focussing my studies on human rights and the regulation of transnational enterprises. I suspected that a career in law was the best opportunity to apply these interests in practice; however, as a non-law graduate I was reluctant to immediately volunteer for the expense and stress of two more years of study in the form of the GDL and LPC. So, after graduating, I moved abroad to pursue a career playing and coaching rugby; the COVID-19 pandemic put paid to that ambition but provided me the opportunity to start an online law conversion.

 I applied for the role at HMRC as I thought that first-hand experience of the legislative process and regular precedent-setting litigation would provide a great opportunity to develop my career as a solicitor; but also because the tax arena seemed to offer a lot of variety, encompassing my interests in both public law and commercial questions.

All trainees start in litigation for their first year; trainee solicitors remain within HMRC, while pupil barristers spend six months seconded to Chambers. My first seat was in VAT litigation, so after three years of intensive study, I arrived at HMRC braced for mountains of paperwork and long days of dense tax calculations. Instead, waiting on my desk were various packets of lentil-based snacks and the deceptively knotty legal question; are these crisps, or at least similar to crisps? I spent the seat thinking about other such questions, like what distinguishes cosmetic surgery from medical care. During this seat, I visited the Supreme Court assisting a senior lawyer and saw my own case feature in national newspapers.

For my second seat I applied for HMRC’s Enforcement and Illicit Finance litigation Team. The question for this team was less frequently whether someone owes tax, but how HMRC can actually collect it from them. My tasks ranged from advocating on HMRC’s behalf in the Magistrates Court to instructing counsel at fast pace on High Court proceedings, attending the Court of Appeal and working with international law enforcement to seize overseas assets.

 As a trainee you will be given your own cases to run as part of a cross-HMRC case team with tax and policy experts, so you can stretch yourself in an environment surrounded by expert lawyers and tax professionals, who are all very generous with their time. Your role is to co-ordinate this team and ask the right questions to tease the legal arguments out of your clients. In this respect the skills I developed playing team sports were as important as my legal knowledge.  

In your second year you move into an advisory team. In my first six months I worked on a mix of human rights and technical tax advice as part of the Personal Tax and Welfare team. I drafted my statutory instrument, which was a particular highlight, and fed into a major budget measure. It can feel like a drastic transition from the more adversarial world of litigation, but the training is extensive with HMRC running internal induction courses alongside the wider GLP offering.

The advisory lawyers cover a wide variety of tasks, with my final seat feeling like an entirely new role.  I didn’t study EU or International Law as part of my law conversion, but having the lawyers who drafted the treaties sat next to you in the office is always a good starting point!

Whilst the HMRC training contract will be of particular interest for anyone who wants a career in public law, I think it is really important to understand the breadth of the department’s work. There is regular precedent setting litigation with engages questions of employment and commercial law, and advisory teams that span the breadth of civil and criminal practice.