Sarah is based in the firm’s London office and her practice focuses on tax litigation, investigations and disputes, across all sectors and taxes.
She has extensive experience of high value, complex disputes, covering in particular
- transfer pricing and diverted profits tax (DPT);
- the deductibility of payments, including challenges under purpose-based anti-avoidance rules;
- controlled foreign company (CFC) issues; and
- VAT and other indirect taxes.
Sarah often represents clients before the UK tax tribunals and higher courts. She is recognised as “Up and Coming” in contentious tax by Chambers & Partners.
In addition to her contentious workload, Sarah also advises clients on the tax aspects of a variety of corporate and financing transactions, both domestic and cross-border.
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- Advising Gallaher Limited on a dispute concerning whether the tax treatment of a cross-border intra-group asset transfer is in breach of EU law, which is currently on appeal to the Upper Tribunal, with a reference made to the CJEU for a preliminary ruling.
- Advising various groups on disputes relating to the corporation tax treatment of their UK financing arrangements, including “unallowable purpose” and thin capitalisation challenges.
- Advising various multinational clients on complex, high value disputes relating to transfer pricing, diverted profits tax (DPT), controlled foreign company (CFC) and permanent establishment risk.
- Advising on petroleum revenue tax and capital allowances enquiries and disputes in the energy sector.
- Advising Glencore on its dispute with HMRC in respect of transfer pricing and diverted profits tax.
- Advising Tesco on a dispute with HMRC regarding the VAT treatment of Tesco’s Clubcard scheme, which the Upper Tribunal decided in favour of Tesco in January 2019 (and is not being appealed by HMRC).
- Advising large corporates on tax-related contractual disputes.
- Advising on a number of cases relating to the deductibility of payments, including challenges under purpose-based anti-avoidance rules.
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- Solicitor, England and Wales, 2007
- Legal Practice Course - BPP Law School, 2005
- LLB, Jurisprudence - Balliol College, Oxford University, 2004
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