It must feel pretty good to beat an overreaching state back to its margins. Massey, a QC who enjoys almost mythical status, recently represented the executors of Lord Howard of Henderskelfe’s estate in the Court of Appeal, arguing successfully against HMRC that the sale of the £9.4 million Portrait of Omai by Joshua Reynolds was exempt from capital gains tax. (The Supreme Court has since refused HMRC permission to appeal.)
But it’s inheritance tax where he’s always had a keen interest: ‘It’s a sort of a visceral tax,’ he says.
‘Those who pay it, which is a tiny proportion of the country, resent it bitterly, because it affects them horribly when it does apply. It produces so little in tax terms. One can’t help thinking if it went altogether, it would be easy to make up in basic rate tax or VAT without much of a problem. And yet it sort of sticks like a limpet.’
Insiders single out the ‘exceptional’ Massey’s ‘vast’ experience, personal style and, repeatedly, his grey matter: ‘He has a phenomenal brain when it comes to rural and heritage matters,’ says one. ‘A wonderful brain in a charming man — he is a delight to deal with and always user-friendly in provision of what can be complex tax advice,’ says another.