One minute with Daniella Mandel of Baker McKenzie.
What’s keeping you busy at work?
Litigation on classification of services for VAT purposes, and whether, in light of modern trading platforms, these fall within the scope of VAT exemption for financial services. The case significantly impacts the FS sector in terms of VAT costs incurred by banks and how VAT applies to securities transactions.
What do you know now that you wish you’d known at the start of your career?
If I could share one vital lesson I’ve learned over the years, it would be the transformative power of authenticity. Growing up in apartheid South Africa, with my Jewish heritage, profoundly shaped my understanding of the rule of law, fairness, equity and justice – not merely as abstract concepts but as lived experiences. These experiences imbued in me an infinite determination to advocate on behalf of others, to fight for the values that have guided my life.
Being an excellent lawyer is a prerequisite, but being a trusted adviser is a privilege – one that depends on the ability to genuinely connect with and advocate for those we serve. My journey has taught me that mastering the law is important, but building meaningful relationships based on trust and mutual respect is crucial for foreseeing and managing risk, and achieving successful outcomes.
What are you looking out for in 2025?
In 2025, the landscape for tax disputes and litigation is more complex than ever. Businesses face increasing litigation and reputational risks.
Both direct and indirect tax disputes are becoming more contentious. Businesses face uncertainty, multilateral tax audits and litigious activity from tax authorities in multiple jurisdictions. In the FS industry, the Supreme Court judgment in Target Group Ltd [2023] UKSC 35 has significantly narrowed the VAT exemption for payment activities. Additionally, cross-border intercompany recharges pose significant VAT risks for partially exempt businesses.
HMRC’s stringent approach to tackling tax fraud remains a priority. The new failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023, effective from 1 September 2025, aims to hold large organisations criminally liable for fraudulent activities by associated persons in certain circumstances, and this extends to cheating the public revenue. This requires organisations to implement reasonable fraud prevention procedures to avoid liability, with failure resulting in substantial financial penalties and reputational damage.
A significant concern I foresee is the evolving landscape of double/increased taxation, particularly following the current US administration’s approach. I anticipate that businesses will prioritise tax certainty – for example, by seeking advance clearances, APAs, wherever possible.
You might not know this about me but...
I’m deeply committed to making a meaningful impact within Baker McKenzie and the broader legal industry. As the Pro Bono Lead for the London tax team, I’ve contributed to various initiatives, earning a People Award for my efforts. One initiative I’m most passionate about is co-leading the Justice in Action Pro Bono Sprints globally, with volunteers from Baker McKenzie and clients working together on substantive pro bono projects requiring urgent advocacy.
I sit on the Steering Committee for Baker Wellbeing, to help nurture top talent, and I also serve on the Steering Committee for the London Jewish Legal Network, focusing on the ERG Alliance, to promote equity in our communities.
Finally, I host the Financial Institutions VAT & Wine Group, bringing together Heads of Tax, senior in-house tax professionals, and market leaders to discuss the latest VAT issues affecting the industry.
One minute with Daniella Mandel of Baker McKenzie.
What’s keeping you busy at work?
Litigation on classification of services for VAT purposes, and whether, in light of modern trading platforms, these fall within the scope of VAT exemption for financial services. The case significantly impacts the FS sector in terms of VAT costs incurred by banks and how VAT applies to securities transactions.
What do you know now that you wish you’d known at the start of your career?
If I could share one vital lesson I’ve learned over the years, it would be the transformative power of authenticity. Growing up in apartheid South Africa, with my Jewish heritage, profoundly shaped my understanding of the rule of law, fairness, equity and justice – not merely as abstract concepts but as lived experiences. These experiences imbued in me an infinite determination to advocate on behalf of others, to fight for the values that have guided my life.
Being an excellent lawyer is a prerequisite, but being a trusted adviser is a privilege – one that depends on the ability to genuinely connect with and advocate for those we serve. My journey has taught me that mastering the law is important, but building meaningful relationships based on trust and mutual respect is crucial for foreseeing and managing risk, and achieving successful outcomes.
What are you looking out for in 2025?
In 2025, the landscape for tax disputes and litigation is more complex than ever. Businesses face increasing litigation and reputational risks.
Both direct and indirect tax disputes are becoming more contentious. Businesses face uncertainty, multilateral tax audits and litigious activity from tax authorities in multiple jurisdictions. In the FS industry, the Supreme Court judgment in Target Group Ltd [2023] UKSC 35 has significantly narrowed the VAT exemption for payment activities. Additionally, cross-border intercompany recharges pose significant VAT risks for partially exempt businesses.
HMRC’s stringent approach to tackling tax fraud remains a priority. The new failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023, effective from 1 September 2025, aims to hold large organisations criminally liable for fraudulent activities by associated persons in certain circumstances, and this extends to cheating the public revenue. This requires organisations to implement reasonable fraud prevention procedures to avoid liability, with failure resulting in substantial financial penalties and reputational damage.
A significant concern I foresee is the evolving landscape of double/increased taxation, particularly following the current US administration’s approach. I anticipate that businesses will prioritise tax certainty – for example, by seeking advance clearances, APAs, wherever possible.
You might not know this about me but...
I’m deeply committed to making a meaningful impact within Baker McKenzie and the broader legal industry. As the Pro Bono Lead for the London tax team, I’ve contributed to various initiatives, earning a People Award for my efforts. One initiative I’m most passionate about is co-leading the Justice in Action Pro Bono Sprints globally, with volunteers from Baker McKenzie and clients working together on substantive pro bono projects requiring urgent advocacy.
I sit on the Steering Committee for Baker Wellbeing, to help nurture top talent, and I also serve on the Steering Committee for the London Jewish Legal Network, focusing on the ERG Alliance, to promote equity in our communities.
Finally, I host the Financial Institutions VAT & Wine Group, bringing together Heads of Tax, senior in-house tax professionals, and market leaders to discuss the latest VAT issues affecting the industry.
2734558d-601b-48a3-8ae3-ae3513a00429.tmb-editorspic.jpg?sfvrsn=1fc4692d_1)
