Tax Cases Update
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Wednesday 6 April 2022
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6:00 pm to 8:00 pm
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Tax Cases Update

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Thomas Chacko
Thomas Chacko
Barrister, Pump Court Tax Chambers

Thomas advises and litigates on all aspects of direct and indirect tax with a particular interest in small and medium sized businesses and partnership structures. According to www.pumptax.com, Thomas is representing the Crown in several of the major cases testing the taxation of partnerships and LLPs (BlueCrest; HFFX; Odey Asset Management) and regularly advises on matters of partnership taxation including questions of the existence of a partnership or the consequences of incorporating a partnership into a limited company or transferring a trade to an LLP.

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Elizabeth Wilson KC
Elizabeth Wilson KC
Barrister, Pump Court Tax Chambers

Elizabeth is an experienced litigator and advises on all aspects of direct tax. She has a particular interest in IHT business property relief and acted for the taxpayer in the Balfour case.

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Angie Lam
Angie Lam
Tax and Accounts Trainee, Alliotts

Angie is a dual tax and accounts trainee at Alliotts LLP. She has had 3 years’ experience in the financial services industry including a placement year which provides experience across tax, accountancy, and audit disciplines.

Angie is working concurrently towards ACA and CTA qualification under the joint ACA-CTA pathway from August 2021. This study route will enable her to qualify as a Chartered Accountant and Chartered Tax Adviser.

Whilst working as a member of the corporation tax team at Alliotts LLP, Angie has completed both the certificate and professional level exams of her ACA qualification and is currently studying towards her advanced level exams in July 2024. For her CTA qualification, she has passed the Professional Responsibilities and Ethics CBE as well the Advanced Technical OMB exam and will be sitting the final CTA exam in 2025.

Angie graduated from the University of Surrey with a First-Class honours degree in Business Management. Her degree included a placement year completed at Alliotts’ Guildford branch as an accounts/audit assistant. After graduating, Angie was offered a position and decided to join Alliotts’ London tax team.

Angie currently operates mainly within the corporation tax team, assuming responsibility for a wide-ranging portfolio of clients, including the media sector. This includes dealing with creative media tax reliefs, which is a changing landscape.

Her diverse role involves compliance work and tax consultancy including technical research for clients as well as advisory reports; finding resolutions to complex scenarios and so much more.

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John Lovell
John Lovell
Managing Director

John is the Managing Director at Lovell Consulting and has 30 years’ experience as a capital allowances specialist.

John trained with Arthur Andersen and helped found the capital allowances team. At the time, Andersen’s were the first accounting firm to set up a capital allowances specialist team and employ chartered surveyors and train them in taxation.

John later formed Lovell Consulting, which has specialised in capital allowances for over 20 years. John qualified as a chartered quantity surveyor at McBains Cooper. John was educated at Reading University where he gained a First Class honours degree in Quantity Surveying. He gained a scholarship to Oxford University Green Templeton College and attained a Master of Philosophy degree in Management Studies. John is a Chartered Surveyor.

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Nick Wright
Nick Wright
Associate Director, Jerroms Miller

Nick Wright is an Associate Director in the Corporate Tax team at Jerroms Miller, which he joined in 2019. He provides specialist corporate tax advice in areas such as transactions tax, company reconstructions and Employee Ownership Trusts, Employment Related Securities and employee share schemes both to individuals and to accountants and solicitors requiring support for their own clients.

Nick particularly enjoys finding solutions to planning projects in often very technical/complex taxation areas, as well as supporting clients to achieve the optimum solution to their business tax issue, whether that relates to selling their business, demerging, or rewarding employees.

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Anthony Lalsing
Anthony Lalsing
Partner, Menzies LLP

Anthony Lalsing is a Tax Partner at Menzies LLP where he heads up the Innovation and R&D team, a specialism responsible for generating significant tax reliefs for its clients including those operating in both the manufacturing and technology sectors. With over 15 years’ experience advising corporate clients and owner managed businesses, helping them to mitigate tax through commercial tax planning, Anthony has a passion for ensuring businesses benefit from the significant tax advantages available under the R&D tax relief and Patent Box regimes.

Anthony qualified as a chartered accountant in 2008 before specialising in tax and qualifying as a chartered tax advisor in 2009. He was a finalist in the 2017 Tolley’s Taxation Awards for the Taxation’s Rising Star award.

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Aarti Varia ACA
Aarti Varia ACA
Founder, iTax Advisors

Aarti is a qualified accountant, with over 20 years experience gained within one of the Big 4 Accountancy practices. Specialising in R&D (Research and Development) Tax incentives, Aarti has worked with some of the largest companies in the UK, securing over £100m in R&D cash refunds.

In late 2019 Aarti founded iTax Advisors, a specialist R&D Tax consultancy. With a client portfolio of SMEs ranging from start-ups to listed companies across the Tech, Manufacturing and Construction sectors, Aarti has already secured over £3.5m in cash refunds for these companies. For some, this 3x what they were previously claiming.

Aarti provides an all-rounded service that looks beyond R&D Tax. Through her in-depth work with each business, she has identified other tax efficiencies which her clients have benefited from, including R&D allowances, Patent box reliefs amongst others.

Aarti is a keen supporter of GOSH and also works closely with charities in Africa to ensure children there receive clothing and educational material to facilitate their scholastic journey.

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Sati Virdee CTA ATT(Fellow)
Sati Virdee CTA ATT(Fellow)
Director, Citroen Wells

Sati has over 25 years’ experience in the field of Private Client Tax covering personal tax advisory, capital gains tax planning, HMRC enquiries, international aspects of domicile, residency and the remittance basis of taxation and estate planning solutions. She frequently works with UK and non-UK domiciled clients providing advice on how the complex UK tax rules impact their financial transactions.

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Suraj Patel ACA
Suraj Patel ACA
Partner, Lawrence Grant

Suraj completed his Masters in Accounting and Finance, before qualifying as a Chartered Accountant in 2020. He joined Lawrence Grant in the same year and has progressed to the role of Partner.

Suraj has a passion for both tax and solving problems. Together, these assist clients with strategic tax planning and ensuring tax compliance simultaneously.

He has knowledge and experience with tax planning and compliance, for both individuals and corporates, with UK and international aspects. He deals with complex areas such as:

  • residency and domicile tax matters,
  • high net worth individuals with offshore investments and structures,
  • internationally mobile employees,
  • owner-managed businesses’ tax planning
  • group reorganisations - including seeking appropriate clearances from HMRC.

Suraj also relishes working with entrepreneurs and owner-managed businesses, with strategic planning and analysis to grow their businesses and increase profitability.

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Clair Dart FCA CTA
Clair Dart FCA CTA
Partner and Head of Corporate Tax, Alliotts

Corporate Tax and VAT specialist Clair Dart was promoted to Partner and Head of Corporate Tax at Alliotts in 2022. Clair leads in a wide range of interesting work, much of it with an international flavour. Through developing relationships with Alliotts overseas associates and attending conferences Clair has access to a reliable worldwide network of advice.

Clair heads up and mentors a team of Corporate Tax advisors and collaborates with partner specialists in other areas as most transactions will have a corporate tax implication. Clair also specialises in VAT matters including UK, cross border and customs duty issues.

Clair joined Alliotts after spending two and a half years at a Top 30 central London firm where she looked after both inward investment companies and various entrepreneurial entities. During this time Clair built on the knowledge she gained over the previous 10 years at a large regional practice whilst training as a Chartered Accountant and Chartered Tax Advisor (and achieving prize-winning scores in her final ACA exams).

Clair is passionate about investing time in understanding her clients and their businesses. This equips her to be able to provide practical advice appropriate to a client’s circumstances, whilst ensuring that they understand matters thoroughly and receive the personal service that they deserve.

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Sean Randall
Sean Randall
Partner, Blick Rothenberg

With 23 years’ experience advising developers, investors, occupiers, funds and individuals on stamp duty in connection with real estate transactions, group reorganisations, corporate reconstructions and capital markets matters, Sean is widely consulted on all areas of stamp duty work. He has contributed to the development of government policy, tax authority practice and statute on stamp duty, and written/edited the leading textbook on stamp duty – Sergeant & Sims on Stamp Taxes – a textbook especially for conveyancers – The Stamp Duty Land Tax Handbook: A Guide for Residential Conveyancers – and the SDLT chapter in Tolley’s Tax Planning 2022-23.

He is a Fellow of the Chartered Institute of Taxation, the Chair of the Stamp Taxes Practitioners Group and a former winner of Taxation’s Tax Writer of the Year.

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Sam Wightman
Sam Wightman
Corporate Tax Assistant Manager, Jerroms Miller

Sam has specialised in corporate tax for around three years and is soon to qualify as a Chartered Tax Adviser (CTA). He enjoys the problem-solving aspect of tax, and the intricacies of working through legislation to deliver the best service.

Jerroms Miller Specialist Tax provide corporate tax advice relating to:
• Buying and selling businesses
• Group reorganisations
• Mergers and demergers
• Incentivising employees
• Anti-avoidance legislation
• Employee Ownership Trusts

Approachable, friendly and professional, our team have extensive experience of advising businesses of all sizes and across all sectors to find bespoke solutions to the most complex tax scenarios.

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Pete Miller (CTA) Fellow
Pete Miller (CTA) Fellow
Head of Corporate Tax, Jerroms Miller

Pete began his career with the Inland Revenue in 1988 with roles in tax districts in Birmingham and London before spending several years in head office, culminating as the Inland Revenue's expert on the rules for company distributions and advance corporation tax. Since going into private practice 25 years ago, Pete has worked for Big 4 firms and run his own business for 11 years, advising a wide range of clients from owner managed businesses to the largest corporate groups. While Pete has provided in-depth tax advice on all aspects of corporation tax, he specialises in the taxation of corporate transactions and the consequences to shareholders, including buying and selling companies, mergers and demergers, and all forms of corporate reorganisation.

Pete has always taken an interest in tax policy, having had policy roles with the Inland Revenue. In recent years, his involvement, both personally and through his CIOT positions, has helped shape several aspects of the current tax regime, including the 2011 changes to the capital gains tax exit charges and the amended joint-venture and partnership rules for entrepreneurs’ relief (now business asset disposal relief). Pete is Chair of the CIOT's Owner Managed Business Tax Technical Committee, as well as being a member of the Tax Policy and Oversight Committee and of the Education Committee. He is also a member of the ICAEW Tax Faculty Business Tax Committee.

Jerroms Miller Specialist Tax provide corporate tax advice relating to:
• Buying and selling businesses
• Group reorganisations
• Mergers and demergers
• Incentivising employees
• Anti-avoidance legislation
• Employee Ownership Trusts

Approachable, friendly and professional, our team have extensive experience of advising businesses of all sizes and across all sectors to find bespoke solutions to the most complex tax scenarios.

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Dr Claire Skipper MSci PhD ACA CTA
Dr Claire Skipper MSci PhD ACA CTA
Senior Manager, Dixon Wilson

Claire Skipper joined Dixon Wilson after a brief career in academia and now focuses her analytical and logical mindset on solving the technical problems of her clients. 

Individuals with their associated Trusts, Estates and companies make up the majority of Claire’s portfolio.

Claire specialises in complex UK tax compliance, advisory and planning including in relation to Offshore/Non-dom matters, Inheritance Tax (IHT), Private Equity and divorce.

However, Claire’s dual qualification and breadth of knowledge mean that you have a single point of contact for both your complex tax problems as well as the accounts preparation of your Trust, charity or company. 

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Daniel Hetherington
Daniel Hetherington
Herald Wealth Management

Dan Hetherington is a Chartered Financial Planner and a Fellow of the Chartered Institute of Insurance.

Dan is the Principal of Herald Wealth Management, with the head office based in Shrewsbury, providing high level advice to senior members of the NHS Pension Scheme.

He has presented to thousands of Consultants, GP’s, Dentists and senior managers in the NHS, through combined seminars with NHS Trusts and Private Hospitals, across the UK.

We work closely with our clients and their accountants, to provide clarity on the exceptionally confusing NHS Pension Scheme, helping them to navigate as effectively as possible through to retirement.

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Joanna Gaudoin, Managing Director - Inside Out Image
Joanna Gaudoin, Managing Director - Inside Out Image

Joanna is the Managing Director of Inside Out Image and author of the bestselling book “Getting On: Making work work”. Joanna helps companies and individuals develop highly effective professional communication and relationship skills for greater business success.

Joanna’s clients include Forsters LLP, Staples Inn Actuarial Society, Joelson Law, Mastercard, Thomas Miller, HSBC, Marcuson Consulting and Allied Irish Bank, as well as over 150 individual clients. She helps companies achieve success by equipping their people with these crucial professional skills. She also works with individual clients, in a private capacity, on their career development, helping them get unstuck, move forward, and achieve their career goals.

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Karyn Jones
Karyn Jones
Partner, Shaw Gibbs

Karyn joined Shaw Gibbs in December 2017. She has over 25 years’ experience in the insolvency space, having previously run her own practice and been a qualified Insolvency Practitioner (IP) and Partner with a boutique insolvency firm.

Karyn is licensed by the Insolvency Practitioners Association (IPA) to act as an Insolvency Practitioner, which allows her to hold insolvency appointments in relation to companies, individuals and partnerships.

She is a member of the IPA Examination Committee, writing questions and marking papers for the CPI Exam.

Karyn advises Companies and Individuals on formal insolvency procedures, informal negotiations with creditors including HMRC, as well as solvent liquidations. She is experienced in working on a consultancy basis to assess the financial status of businesses and to ascertain the measures required to ensure viability. Karyn is often appointed by major creditors to act as Trustee or Liquidator

In her spare time, Karyn enjoys doing her bit for charity, and has completed 12 international charity bike rides in countries such as Madagascar, Sri Lanka and Brazil. Spending time with her family and dog are high on her list of priorities.

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Thomas Dalby
Thomas Dalby
Head of Employer Solutions, Haines Watts

Thomas is a leading share scheme expert and CTA who works with ambitious startup and high growth businesses and their directors. He provides comprehensive tax advice on remuneration, including tax relief available on shareholdings, employee share option plans and bespoke share incentive solutions, along with optimisation of company structures.

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Max Schofield
Max Schofield
Barrister, 3 Paper Buildings

Max Schofield is a commercial barrister with particular expertise in indirect tax disputes, and is ranked by the 2022 Legal500 directory as a “Rising Star” in the field of VAT.

Max has been instructed to advise and appear on a broad range of tax cases concerning VAT, SDLT, Excise Duties, Remote Gaming Duty, and has a busy practice far beyond his call.

His clients have included social media platforms, television channels, food and drink manufacturers, online casinos, and universities.

As a co-editor of the long-running publication “A Handbook of EU VAT Legislation” (Wolters Kluwer), Max keeps his finger on the pulse with regards to changes to VAT law. He is widely published and often invited to give guest lectures at universities and to present papers at symposia.

Max is regularly contacted to provide expert commentary on changes and trends in tax law and policy.

Prior to coming to the Bar, Max was a tax editor for Bloomberg BNA and a paralegal in Macfarlanes LLP’s litigation department and Clyde & Co LLP’s professional negligence department. He accepts instructions for matters in the High Court, County Court, Court of Appeal, First Tier Tribunal (Tax) and Upper Tribunal (TCC).

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Paul Howard FCA CTA
Paul Howard FCA CTA
Director, Dixon Wilson

Paul is a Chartered Accountant and Fellow of the Chartered Institute of Taxation, with over 30 years’ experience in advising clients and other professionals on a wide range of complex tax issues. He joined Dixon Wilson as a director in 2019, where he provides tax technical support for the firm.

He focuses on wealthy entrepreneurs, advising on tax issues arising in relation to their business and to their personal tax planning. He advises on the structuring of transactions, and strategic planning for the longer term. While focusing on UK taxation, he also advises on how the UK tax system functions on an international basis.

He is a well-known lecturer covering a range of taxes, and often speaks at events around the country for the Chartered Institute of Taxation. He was co-author of Tolley’s Tax Planning for Owner Managed Businesses, and writes articles for various professional publications.

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Alison Ralston CTA
Alison Ralston CTA
Consultant, Yes Tax

Alison left university before moving to Birmingham and working and qualifying as a Chartered Tax Adviser with PwC back in 1998. On budget night, back in 1999, new legislation concerning tax relief on R&D expenditure caught her eye - and she has never looked back! Alison went on to build a national R&D tax service at PKF before starting her own business, HowarthLynch, in 2009.

By 2014, Alison’s business was one of the largest bespoke tax practices in the UK. Her ambition was to develop a larger specialist tax practice and be the largest independent tax firm in the UK. To realise this ambition, Alison sold her practice to a Fortune 500 company.

Alison took a break from corporate life in 2018 to pursue her philanthropic pursuits. She is a strategic thinker and motivational leader who likes to lead by example inspiring teams to deliver. She has a proven track record of commercial success - leading, motivating and selling. She uses these skills in the boardroom to make real changes in her frontline charity work.

Alison is the founder and trustee of the Guiding Light Foundation which now runs through the core of YesTax.

Alison’s main area’s of tax specialities are Capital Allowances, R&D Tax Relief and Patent Box.

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John Moxon FCA
John Moxon FCA
Founder and Director, YesTax

John is an ICAEW Chartered Accountant who has solely specialised R&D tax relief since 2009. He was a Director at the UK’s first R&D tax consultancy firm and his next role saw him head up one of the UK’s largest R&D tax advisory teams. During this time, he managed a large client portfolio and ran an enquiry resolution service for accountants who had got into a spot of bother with HMRC with their own R&D claims.

In 2019, he formed YesTax which won The Best New Tax Practice award at the 2020 Tolley’s Taxation Awards. John is also a member of the HMRC R&D Communication Forum.

His ability to give clear and unambiguous tax advice is popular with his clients – many of whom he has advised for over a decade.

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Mala Kapacee CTA
Mala Kapacee CTA
Director, London Tax Network Ltd

Mala is a Chartered Tax Adviser and non-practising Solicitor and Accountant. She specialises in preparation of disclosures to HMRC and resolution of tax enquiries and CoP8 and 9 Investigations. She has experience in a range of situations – self-employment, property, owner managed businesses, non-UK domiciled individuals – and taxes; direct income taxes as well as PAYE, VAT and SDLT.

She is a well-known tax author, having been published by Taxation MagazineInternational Tax Review, Bloomberg Tax, Bloomsbury Professional and Tax Adviser. Mala founded the London Tax Society in 2017 and actively encourages networking and technical development for young professionals.

Mala lectures regularly for professional bodies including the CIOT, CIMA and the ICAEW. She was a finalist for “Best Rising Star in Tax” as part of Tolleys Taxation Awards 2020. The Awards are known for identifying excellence in tax. Being shortlisted demonstrates Mala’s commitment to the tax profession as well as her technical excellence as supported by testimonials from clients and other tax experts.

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Kevin Offer CTA FCA
Kevin Offer CTA FCA
Partner, Hardwick and Morris LLP

Kevin is a partner at Hardwick & Morris LLP, leading the tax advisory offering of the practice as well as providing tax advice and support to Private Clients and intermediaries/advisers who need additional tax support for themselves and their own clients. His specialisations include:

  • Taxation of high net-worth individuals, non-domiciled individuals, international families and their business/investment interests.
  • Advice to trustees on international tax matters.
  • The international taxation of performance, recording, endorsements/sponsorship and other income/assets for sportspersons/musicians and other entertainers.
  • Experience in back duty and Investigation work including negotiating settlements with the UK tax authorities.

He is a regular speaker at international conferences and writes for UK and international professional publications.

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John Hood
John Hood
Partner, Moore Kingston Smith

John Hood is Moore Kingston Smith’s tax dispute resolution specialist. He is expert at dealing with complex and serious tax investigations launched by HMRC, settling matters on a civil basis. In the most serious cases, this can involve limiting the risk of the enquiry being escalated to a criminal investigation. John genuinely relishes the challenge of unravelling convoluted tax scenarios and establishing a mutually satisfactory endgame.

John aims to minimise the risk for his clients, while also ensuring HMRC is operating within the tax legislation. His clients are generally owner-managed businesses and their families, high net worth individuals and those with complex affairs. Mostly clients are referred to John through their professional advisers. Some might already be the focus of an HMRC investigation, while others might want to make a voluntary disclosure to regularise the past.

With more than two decades of experience in tax dispute resolution, John has vast knowledge of HMRC’s administration and enforcement procedures. Having also previously worked at HMRC in the compliance arena, John has a deep understanding of the key strategies needed to achieve the best result for his clients.

From his clients’ point of view, John has a calming effect at what is often a stressful and emotionally charged time. They are reassured by the fact that he focuses on negotiating the best outcome for both them and HMRC. His easy manner, knack of explaining things in everyday language and sense of humanity are also valued by his clients.

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Caroline Fleet CTA
Caroline Fleet CTA
Partner, Crowe UK

Caroline is Head of Real Estate and Construction sector and a Corporate tax partner at Crowe UK.

Her clients range within the Corporate world across a number of industries and include property developers, international real estate investors and significant property occupiers (such as hotels and care homes). She has particular expertise in advising on the most appropriate structure taking into the business model, the various stakeholders and all of the taxes involved. Taxation of property has become increasingly complicated over the last few years with more taxes and higher rates and she has extensive experience in assessing the interaction of the various taxes.

Caroline is a member of the CIOT Property Committee and Stamp Taxes Practitioners Group.  She regularly speaks to and writes articles for trade press.

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Tom Wallace TEP
Tom Wallace TEP
Director, WTT Consulting

Tom started his career at the Inland Revenue (now HMRC) where he trained as an inspector of taxes.  He has investigated businesses in all the customer segments, from FTSE 100 companies to small local businesses and everything in between.  After leaving HMRC he joined WTT Consulting where he is director of tax investigations and focuses on resolving enquiries for those who have used tax structures, particularly disguised remuneration schemes.  He also undertakes private client advisory work, specialising in trust and estate planning.

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Michaela Lamb
Michaela Lamb
Partner, Carter Backer Winter

After qualifying as a Chartered Accountant in 2005, Michaela chose to specialise in tax because it allowed her to become more involved with her clients, helping them address the challenges presented by the ever-changing tax landscape.

She is one of CBW’s more colourful Partners, whose main goal is making tax a little less daunting for her clients, by providing straightforward, practical advice and support.

Michaela is a full member of the Society of Trust and Estate Planners (STEP) and advises on all Private Client issues for UK and offshore individuals, and for Trusts and Estates. She also leads CBW’s Probate service. Michaela specialises in working with families to achieve tax efficient (often inter-generational) planning, as well as providing tax advice when the situation changes, for example on marriage and divorce or if someone is coming to (or leaving) the UK.  Michaela often works with people who need to take UK tax advice for the first time, and believes that advice should be put simply and clearly to avoid any doubt.

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Keith Gordon
Keith Gordon
Barrister, Temple Tax Chambers

Keith Gordon qualified as a chartered accountant and chartered tax adviser before retraining for the Bar. Since 2006, he has specialised in assisting taxpayers in disputes with HMRC and regularly attends courts and tribunals, ranging from the County Court to the Supreme Court. High profile cases include representing Kaye Adams (Atholl House Productions Ltd) and Eamonn Holmes (Red, White & Green Ltd) in their IR35 disputes in the Court of Appeal and Upper Tribunal.

He advises in all tax-related matters, extending to social security contributions and benefits as well as professional negligence matters, where he acts for claimants and defendants alike.

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Dilpreet K. Dhanoa
Dilpreet K. Dhanoa
Barrister, Field Court Tax Chambers

Dilpreet K Dhanoa has a diverse practice in Revenue law across both indirect and direct taxes, nationally and internationally. She joined Field Court Tax Chambers from private practice working in international arbitration and litigation, focusing on commercial disputes and advising on the implementation of VAT in the Middle East. She has appeared in all levels of Court up to the Court of Appeal. Dilpreet has a broad advisory practice and regularly undertakes litigation. She is a chapter editor for Gammie & De Souza on Land Taxation and also a regular contributor to British Tax Review, Taxation and Tax Adviser. Dilpreet sits on the Advisory Boards of Oxford Women in Law, Young ITA and H&I on European Taxation. Dilpreet holds an MSc in Tax Law from the University of Oxford and prior to joining the independent Bar, she qualified as a Chartered Tax Advisor with a Big-4 Accounting firm, specialising in the taxation of financial instruments and real estate.

Education

  • Academic qualifications: LLB (Hons.), MSc (Oxon.), MSc Taxation (Oxon.)
  • Professional qualifications: CTA (CIOT), BVC
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Patrick Boch
Patrick Boch
Barrister, Old Square Tax Chambers

Patrick Boch is a Barrister, Old Square Tax Chambers. He practices in all areas of tax law, with a particular focus on tax litigation and private client matters. Patrick is an experienced advocate, appearing regularly before the courts and tribunals. He is adept at incisive witness examination and has also acted as an expert witness on UK tax law in a foreign jurisdiction.

As an ex-HMRC lawyer, he has considerable knowledge of how HMRC operate and approach litigation. His LL.M. dissertation (which achieved a first-class mark) was on the GAAR and he has extensive experience of dealing with avoidance matters.

Apart from tax, he has a practice in insolvency (especially in HMRC-led petitions), traditional chancery (particularly probate), and general commercial law.

He is dual-qualified as an Indian advocate, and can advise on Indian tax law and the legal and commercial environment in India more generally. Having completed his LL.M. in Denmark, and being fluent in Danish, he is also able to offer insight on matters with a Scandinavian connection.

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Constantine Christofi
Constantine Christofi
Senior Associate, RPC

Constantine is a Senior Associate in RPC’s Tax Disputes team and has assisted clients in both civil and criminal litigation against HMRC.

Constantine advises corporates and high net worth individuals on all aspects of corporate and personal tax. He has extensive experience in challenging HMRC decisions on public law grounds by way of judicial review.

Constantine has also played a key role in achieving effective settlement outcomes for some of RPC’s major corporate clients and has conducted complex litigation before the Tax Tribunals and Higher Courts.

Constantine is a regular contributor to professional journals and to RPC’s Tax blog, Tax Take.

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Angela Ferguson
Angela Ferguson
Director, Saffery Champness

Angela is a Director in Saffery’s Manchester office, specialising in employment taxes. She has trained and worked within Big Four firms since 1994. She covers the whole of the UK in her role as the National Head of Employment Taxes here at Saffery’s. Angela advises clients across all sectors in respect of a variety of employment tax issues.

Angela is a regular speaker at internal and external events, often talking at industry network meetings, tax body gatherings and government departmental events.

Key Experience:

  • Assisting clients with the implementation of the IR35 legislation, including designing new processes in order to evidence compliance in the public sector since April 2017, auditing those processes and preparing the private sector for the changes to be implemented from April 2020
  • Supporting clients with their compliance with the NMW regulations
  • Reviewing and structuring tax-efficient benefits such as salary sacrifice arrangements
  • Compliance in redundancy and termination situations, including advice regarding PENP
  • Bonus and pension planning
  • Managing HMRC PAYE reviews
  • Construction Industry Scheme compliance
  • Advice on best practice for expenses policies/processes, reporting benefits in kind and PSA calculations.
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Ximena Montes Manzano
Ximena Montes Manzano
Barrister, Temple Tax Chambers

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 Public Access Scheme in appropriate cases.

Since joining Chambers, Ximena has taken a keen interest in all aspects of tax law with a focus on litigation and alternative dispute resolution. Ximena has represented taxpayers in direct and indirect tax appeals in the First-tier Tribunal and Upper Tribunal as well as Judicial Review proceedings and appeals to the Higher Courts. Ximena was also appointed and appeared as a First-tier Tribunal Advocate (Amicus Curiae) in a test case about the nature and effect of a P800 form and the Tribunal’s jurisdiction to hear public law arguments.

Ximena has been instructed several times by the Chartered Institute of Taxation, the Association of Taxation Technicians and the joint professional bodies’ working party to advise on the draft guidance on “Professional Conduct in relation to Taxation” and the “Professional Rules and Practice Guidelines” amongst others. In addition to insight on professional conduct matters, Ximena also has expertise on all areas of professional negligence (Accountants, tax advisers, solicitors etc.) with emphasis on limitation, date of knowledge, causation and mitigation issues.

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Michael Thomas
Michael Thomas
Barrister, Pump Court Tax Chambers

Michael Thomas advises and litigates in relation to all areas of the UK tax code. His practice covers business tax, private client work and VAT. He has a particular interest in property tax and has advised on some of the UK’s largest real estate transactions and development projects.

It has been said that “he has a strong tax record of success in tax litigation”, is “ahead of the game when it comes to property taxation” and “the go-to man for stamp duty land tax.” Michael sits on the tax committee of The Country Landowners Association.

When litigating Michael is mindful that the best result for a client rarely involves a contested hearing. He has a strong track record of achieving favourable outcomes without a trial including in relation to VAT (where a 7- figure repayment was received by a FTSE 100 company) and on employment taxes (where HMRC rescinded an assessment of several hundred thousand pounds following an internal review).

Michael has significant experience of litigating the application of anti-avoidance rules.

His litigation practice also includes defending professional negligence actions, ligating tax deed claims and acting in civil fraud investigations under code of practice 9.

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Kelly Stricklin-Coutinho
Kelly Stricklin-Coutinho
Barrister, 39 Essex Chambers

Kelly Stricklin-Coutinho is a barrister at 39 Essex Chambers where her practice focuses on tax disputes (direct and indirect), commercial disputes and EU law (including state aid).

Her recent matters include VolkerRail Plant Ltd (& Ors) v HMRC [2023] EWHC Civ 210 on group relief, VAT disputes, environmental tax disputes, financial services tax disputes, advising in relation to environmental tax and inheritance tax in innovative biodiversity projects, acting for the British Medical Association in relation to challenges to the tax treatment of defined benefit statutory pension schemes, advising on an expert determination relating to Irish Law on REITS, and co-mediating with HMRC.

She taught tax law courses at King’s College London and Birkbeck for over 10 years. She is called to the Bar in the Republic of Ireland and is a CEDR accredited mediator. She is ranked in the Legal 500 and Chambers & Partners.

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Rachel Cook
Rachel Cook
Senior Associate, Peters & Peters Solicitors LLP

Rachel acts for companies and individuals investigated and/or prosecuted by UK and foreign authorities for tax irregularities. As well as criminal investigations, her experience includes the Contractual Disclosure Facility (also known as Code of Practice 9), where tax evasion is suspected by HMRC, advising on the corporate offence of failing to prevent the facilitation of tax evasion and assisting clients who are requested or compelled by HMRC to provide information and/or materials about a third party. Rachel has experience acting for individuals in both restraint and confiscation proceedings and has prepared clients for the eventuality of Unexplained Wealth Orders.Rachel acts for a trader being prosecuted by the FCA for insider dealing. Rachel also advises regulated individuals subject to oversight and/or investigation by the FCA and assists individuals who are witnesses in FCA prosecutions. Rachel acted for a leading bank in a Libor investigation.Money laundering issues can arise in almost all white-collar cases and Rachel has acted for a number of individuals charged with this offence. She frequently advises individuals and corporates on compliance with money laundering regulations.Rachel has successfully acted for individuals that are the subject of mutual legal assistance requests in the UK and/or abroad, including successful judicial reviews of the Secretary of State’s decision to act on a request from a foreign state. She also has experience acting for legal and accountancy professionals subject to professional disciplinary proceedings.

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Peter Heslington
Peter Heslington
Partner, Praxis LLP

Peter Heslington is a Chartered Tax Advisor (CTA) and Trusts and Estates Practitioner (TEP).

Pete’s expertise crosses many sectors and taxes.  He focuses on bespoke tax planning and structuring covering corporate tax, mergers and demergers, acquisitions and sales, exit and remuneration planning, share schemes, partnership taxation, investment planning, wills and probate.

Pete has over 20 years of experience advising Owner Managers and High & Ultra High Net Worth Individuals.

Pete holds a degree in Law and Post-Graduate Diploma in Legal Practice.

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