The loan charge: where are we now?
10 June 2019
Sarah advises high net-worth and high profile individuals, charities, partnerships and corporates on all aspects of HMRC interactions, disputes and investigations; including complex technical investigations (“COP8”), cases involving suspected tax fraud (“COP9”), voluntary disclosures, negotiation of penalties and time to pay arrangements, and settlement of individual and corporate participation in marketed tax avoidance schemes (including Disguised Remuneration and EBT’s).
Sarah has also represented individuals under investigation by multiple authorities (Home Office and Charity Commission).
Sarah is a regular contributor to tax and legal publications, and has recorded seminars for STEP, Law Society and Lexis Nexis discussing various matters including marketed tax avoidance and general tax investigation matters.
A recent case in which Sarah advised included a £6m civil settlement for an individual participant in a fraudulent marketed tax avoidance scheme.
Sarah has also recently negotiated a group settlement involving over 50 EBT participants (participants and individuals).
Sarah joined Stewarts in April 2019 after spending 15 years in tax practice (Mazars and BDO), having previously trained at the Inland Revenue (now “HMRC”), Sarah is able to use her understanding of HMRC processes and structure to resolve complex tax investigations.
Sarah is a member of the Association of Taxation Technicians (“ATT”) and Chartered Institute of Taxation (“CTA”).
Sarah’s most recent article discussed the controversial “2019 Loan Charge” in which participants of historic Disguised Remuneration arrangements are facing a significant and arguably retrospective tax charge in relation to past tax planning, covering various technical matters in consideration.
Sarah loves to travel and spends idle moments planning her next adventures. Sarah is a keen amateur interior designer having recently renovated a derelict Victorian house in London, and is currently eying up her next project! Sarah is also a “foodie” and enjoys making her way through the Time Out top 100 London restaurants.