A mix of disclosures for international clients, and corporate tax litigation. I love to draft a good technical letter, but as a Director I spend more time dealing with clients and managing project teams than I do originating documents.
If you could make one change to tax, what would it be?
Better training for HMRC staff, and more direct access for practitioners to those staff. Many HMRC personnel simply don’t have the technical training to understand the questions being asked. Having the person on the other side fully understand what you are talking about makes the process much more efficient for all involved.
What do you know now that you wish you’d known at the start of your career?
That a career is a very long thing, and that you do not have to follow a traditional path to get where you want to go – although it might make things quicker! I don’t have a traditional legal background. I grew up on the West Coast of Scotland where my father initially worked as a welder building giant ship engines, and my mother was a nursing sister for over 30 years – in fact, at one point at the end of her career she was possibly the oldest working nurse in the NHS. As a result I had to find my own path to qualifying. My first degree was in Scots law. Then I moved south and eventually did my E&W law degree through evening classes. Over the years, I worked as a cinema usher, as a director’s PA at PA Consulting, and in IT marketing for Alan Sugar’s Viglen. I spent a year working in pastoral care in a girls’ boarding school to fund my LPC. None of these jobs were a ‘traditional’ preparation for law; however they gave me a wider view of business, and an understanding of people, that has only been helpful since I qualified as a solicitor.
Are there any potential new rules that give you cause for concern?
I have noted the concerns of other lawyers regarding the recent changes in the Civil Procedure Rules on witness statements, as changes implemented in the CPR have a fighting chance of appearing later in the tax tribunals. Given the level of complexity of the matters we deal with, having witnesses in tax appeals being required to draft their own witness statements unassisted would inevitably limit the value of witness evidence in the tax tribunals.
Has a recent change in HMRC practice impacted your work?
I have noticed decreasing consistency at HMRC regarding the use of the Litigation and Settlement Strategy (LSS) – a combination of hiding behind it on the one hand when a taxpayer is seeking to settle a matter, and a refusal to accept that the LSS restrains HMRC’s own actions where taking an action is to HMRC’s advantage. I have seen matters where HMRC have essentially said ‘we want to do this, so we are doing it’, and when challenged on the basis that the LSS does not permit the proposed action, have simply stated that they do not consider themselves bound by the LSS in relation to that point.
You might not know this about me but...
When I was a small girl, I decided that I wanted to be a musketeer. My grandpa made me a wooden sword to practise my fights in the garden. Eventually, however, my parents told me that ‘musketeer’ was not a career choice that was viable in the late 20th century. I was broken-hearted! But when as an adult I moved to London, I managed to combine childhood wish fulfilment with realism by taking up stage fighting as a hobby, and at one point was a certified advanced actor combatant in seven different ancient weapons forms. I still have an enduring love of theatre and live performance, especially where a sword fight is involved!
A mix of disclosures for international clients, and corporate tax litigation. I love to draft a good technical letter, but as a Director I spend more time dealing with clients and managing project teams than I do originating documents.
If you could make one change to tax, what would it be?
Better training for HMRC staff, and more direct access for practitioners to those staff. Many HMRC personnel simply don’t have the technical training to understand the questions being asked. Having the person on the other side fully understand what you are talking about makes the process much more efficient for all involved.
What do you know now that you wish you’d known at the start of your career?
That a career is a very long thing, and that you do not have to follow a traditional path to get where you want to go – although it might make things quicker! I don’t have a traditional legal background. I grew up on the West Coast of Scotland where my father initially worked as a welder building giant ship engines, and my mother was a nursing sister for over 30 years – in fact, at one point at the end of her career she was possibly the oldest working nurse in the NHS. As a result I had to find my own path to qualifying. My first degree was in Scots law. Then I moved south and eventually did my E&W law degree through evening classes. Over the years, I worked as a cinema usher, as a director’s PA at PA Consulting, and in IT marketing for Alan Sugar’s Viglen. I spent a year working in pastoral care in a girls’ boarding school to fund my LPC. None of these jobs were a ‘traditional’ preparation for law; however they gave me a wider view of business, and an understanding of people, that has only been helpful since I qualified as a solicitor.
Are there any potential new rules that give you cause for concern?
I have noted the concerns of other lawyers regarding the recent changes in the Civil Procedure Rules on witness statements, as changes implemented in the CPR have a fighting chance of appearing later in the tax tribunals. Given the level of complexity of the matters we deal with, having witnesses in tax appeals being required to draft their own witness statements unassisted would inevitably limit the value of witness evidence in the tax tribunals.
Has a recent change in HMRC practice impacted your work?
I have noticed decreasing consistency at HMRC regarding the use of the Litigation and Settlement Strategy (LSS) – a combination of hiding behind it on the one hand when a taxpayer is seeking to settle a matter, and a refusal to accept that the LSS restrains HMRC’s own actions where taking an action is to HMRC’s advantage. I have seen matters where HMRC have essentially said ‘we want to do this, so we are doing it’, and when challenged on the basis that the LSS does not permit the proposed action, have simply stated that they do not consider themselves bound by the LSS in relation to that point.
You might not know this about me but...
When I was a small girl, I decided that I wanted to be a musketeer. My grandpa made me a wooden sword to practise my fights in the garden. Eventually, however, my parents told me that ‘musketeer’ was not a career choice that was viable in the late 20th century. I was broken-hearted! But when as an adult I moved to London, I managed to combine childhood wish fulfilment with realism by taking up stage fighting as a hobby, and at one point was a certified advanced actor combatant in seven different ancient weapons forms. I still have an enduring love of theatre and live performance, especially where a sword fight is involved!
