
Overview
Emma has a broad advisory and litigation practice which covers all major areas of UK revenue law including:
- Personal tax
- Corporate tax
- VAT and other indirect taxes
- Stamp duty and SDLT
- Customs and excise duties
Practice
Recent cases
Emma has been involved in a number of cases, including:
- Paragon Customer Communications Ltd v HMRC (FTT) (led by Andrew Hitchmough KC) – VAT, zero-rating
- Albon Engineering and Manufacturing Ltd v HMRC (FTT) (led by Richard Vallat KC) – NICs and PAYE
- Netley v HMRC (FTT) (led by Michael Gibbon KC and James Henderson) – valuation of AIM shares, gifts to charity
- Tinkler v HMRC (UT) (led by Roger Thomas KC) – enquiry notices, agency
- Smith & Nephew Overseas and ors v HMRC (UT) (led by James Rivett) – exchange losses, GAAP compliant accounts
- Prestopets v Director of Border Revenue (FTT) – restoration of goods
- Friends of the Earth v HMRC (FTT) (led by Richard Vallat KC) – VAT, nature of supply
- Franked Investment Income GLO v HMRC (CoA) (part of counsel team including David Ewart KC, Rupert Baldry KC and Barbara Belgrano) – advanced corporation tax, EU law, restitution etc
- HMRC v Raftopoulou (CoA) (led by Michael Thomas) – enquiry notices, closure notices
Recent advisory work
Emma has advised recently on a broad range of topics, including:
- Trusts (UK and offshore) and related family planning (including the effect of the new ‘non-dom’ rules)
- Residence and domicile status
- Partnerships
- Property income
- ATED
- Private residence relief
- BPR and APR planning
- Deeds of variation and other post-death re-arrangements
- Claims under the inheritance (Provision for Family and Dependants) Act 1975
- EBTs
- Entrepreneurs’ relief
- Judicial review of HMRC’s decisions
- Penalties
- Schedule 36 notices
- Discovery assessments
- APNs and Follower Notices
- VAT (including the application of exemptions and time and nature of supply of issues)
- SDLT (including 3% surcharge, partnership rules, sub-sale relief)
- Capital allowances
- NICs and PAYE
- Excise duty
- Customs duty
Career
2018: Appointed Junior Counsel to the Crown – “C” panel
2015: Tenant, Pump Court Tax Chambers
2014/15: Pupillage, Pump Court Tax Chambers
2014: Called to the Bar (Lincoln’s Inn)
Education
2013-2014: Kaplan Law School, London – BPTC (Outstanding)
2012-2013: City University London, GDL/CPE (Distinction)
2007-2011: Balliol College, Oxford – Classics BA, First Class
Scholarships and Prizes
2013-2014:
Lord Denning Scholarship (Lincoln’s Inn)
2012-2013:
Hardwicke Scholarship (Lincoln’s Inn)
Lord Bowen Scholarship (Lincoln’s Inn)
2007-2011:
Robin Holloway Scholarship (Balliol)
Jenkyns Exhibition (Balliol)
Samuel Dubner Prize (Balliol)
Jasper Ridley Prize (Balliol)
Languages
French (conversational)
Italian (basic)
Publications & Talks
- Contributor to the Trust and Estates Law & Tax Journal and Hamilton on Tax Appeals
- Contributor to Hamilton on Tax Appeals
- “Thirty nine years of uncertainty should be brought to an end”. Article in Private Client Business (Sweet & Maxwell)
- Various Lexis PSL updates on taxation of non-domiciles (UK home ownership structures for non-UK domiciliaries- outline; UK home ownership structures for non-UK domiciliaries- table)
- Emma draft the taxation sections of “At a Glance” (a publication for financial remedy practitioners)
- Emma also lectures regularly on a range of tax-related topics.
- “Section 104: returns relating to LLP not carrying on business etc with view to profit”. Article in British Tax Review, No 4, 2020
01 May 2020
Private Client Update: Budget 2020 and recent cases. The recording of this Bridge the Gap seminar is available for purchase here.
September 2019
VAT Conference 2019. This was an all-day conference hosted by Pump Court Tax Chambers.
April 2018
Simmonds & Simmonds Tax Peer Network event on judicial review
The Legal 500 Says..
Private Client: Personal Tax
Ranking: Rising Star, Tier 1
‘Is very thorough and precise in her work and it is always of a very high quality. She will always think through every possible permutation of a tax issue and one is completely confident that she has considered all the angles when she presents her findings.’ (2021)
Related judgments
- Tinkler v HMRC; (SC)30 July 2021
- Mark Shaw (TAL CPT) v HMRC; (UT)28 April 2021
- Hanan V HMRC; (UT)22 June 2020
- Court of Appeal Decision: William Andrew Tinkler v HMRC31 July 2019
- FTT Decision: Baillie Gifford & Co v HMRC25 June 2019
- FTT Decision: Giulio Corrado v HMRC25 April 2019
- Court of Appeal Decision: HMRC v Dr Vasiliki Raftopoulou18 April 2018
- FTT Decision: Paragon Customer Communications Ltd v HMRC28 March 2018
- UT Decision: William Tinkler v HMRC13 March 2018
- FTT Decision: (1) Smith and Nephew Overseas Limited (2) T P Limited (3) Smith and Nephew Finance Holdings Limited v HMRC8 February 2017