PROFILE
Helen is a Partner in the Joseph Hage Aaronson contentious tax team specialising in UK and international tax disputes. She is a Solicitor and Chartered Tax Adviser, a member of the Society of Tax and Estate Practitioners and is a CEDR accredited mediator. She has recently been included in the City Wealth Leaders List Top 100 Private Client lawyers, is included in the Private Client Global Elite Directory 2023 and appears the Tatler Address Book 2023. Helen writes prolifically for numerous tax publications and is an active committee member at the Chartered Institute of Tax and the Worshipful Company of Tax Advisers.
Helen advises both individuals and corporates either engaged directly or as a consultant to an extensive network of professional firms and financial institutions who repeatedly call upon her expertise.
Helen has trained under both Ray McCann and also Peter Vaines when she was the lead associate in R (on the application of Gaines-Cooper) v Commissioners for Her Majesty's Revenue and Customs. She has successfully run numerous residence and domicile cases but will also turn her hand to a wide variety of contentious and advisory tax matters. Helen is an industry leading specialist at running highly technical COP9 investigations where she has a proven track record of successfully negotiating very favourable settlements.
Helen frequently writes for Tax Adviser, Tax Journal and other tax publications. She also edits chapters for the acclaimed Bloomsbury Professional publication Revenue Law: Principles and Practice.
Clients say of her:
Her judgement is razor sharp. Under immense time pressure and navigating complex rules, she speedily formed her opinion, liaised with hostile opposition, and closed the deal in a smart and flexible manner.
The advice Helen provided me with on my technical international tax issues was unbelievably thorough. It put my mind at rest that she did not leave any stone unturned. HMRC interviews were never stressful as Helen was always completely in control.
PROFESSIONAL QUALIFICATIONS
Admitted as a solicitor in England and Wales, 2009
Chartered Tax Adviser, 2012
Society of Trusts and Estates Practitioner, 2015
CEDR Accredited Mediator, 2016
EDUCATION
Cardiff Law School – LPC (Distinction)
University of Maastricht – International Law and European Contract Law
University of Reading – LLB
RELATED ARTICLES
Increased Investment in Personal Tax Compliance in the UK (Published in Thought Leaders 4 Private Client)
Advances in technology and increased international fiscal co-operation have made global personal tax compliance initiatives pop up in abundance in recent years. To compound the issue, the Russian invasion of Ukraine and the corresponding economic fallout prompted domestic governments to increase transparency in relation to investments held by wealthy foreign individuals (with a focus on oligarchs).
In the UK, in the context of the cost-of-living crisis, public opinion certainly seems to be in favour of increased accountability for high-net-worth individuals (eg, on 9 October 2022, 63% of Britons surveyed thought that “the rich are not paying enough and their taxes should be increased”).1
HMRC is one of the most sophisticated tax collection authorities in the world and the department is making significant investments in technology in the field of compliance work; they are well placed to take advantage of new international efforts to increase tax compliance, particularly considering the already extensive network of 130 bilateral tax treaties in the UK (the largest in the world).2 The UK was also a founding member of the OECD’s Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC) forum.
This article discusses the main developments in support of the increased focus on international transparency and personal tax compliance in the UK. There are other international fiscal initiatives, particularly in the field of corporate taxation, but such initiatives are beyond the scope of this article.
It should be noted that a somewhat piecemeal approach, with constant tinkering makes compliance difficult for the taxpayer and is often criticised for lacking the certainty that a stable tax system needs to thrive.
This article was first published with ThoughtLeaders4 Private Client Magazine
Read More
Offshore Structures and Onward Gifts
The so-called “onward gift” tax anti-avoidance rules were introduced by the Finance Act 2018 to complement the changes brought in the previous year aimed at restricting the UK tax privileges afforded to non-UK domiciled individuals. The rules were designed to close some perceived loopholes in relation to the taxation of non-UK resident structures (including but not limited to non-UK trusts). With effect from 6 April 2018, it would no longer be possible for an individual to receive a gift without questioning its providence, particularly where family trusts are involved.
The rules were designed to prevent non-UK structures from using non-chargeable beneficiaries as conduits through which to pass payments in order to avoid tax charges. Gone are the days of “washing out” any trust gains that could be matched to offshore income or gains by prefacing a payment to a UK-resident taxable beneficiary with a non-taxable primary payment to a non-UK resident beneficiary.
“It is notoriously challenging to prove a negative (especially to HMRC) and even more tricky where the taxpayer must speak to someone’s intention other than their own.”
Note that the new rules will apply where funds are received from non-UK resident structures before 6 April 2018 to the extent that they are subsequently gifted after that date.
Read More
Increased Investment in Personal Tax Compliance in the UK
Changes in public opinion, advances in technology and increased international fiscal co-operation have made global personal tax compliance initiatives pop up in abundance in recent years. In addition, the Russian invasion of Ukraine and the corresponding economic fallout have prompted governments to increase transparency in relation to investments by wealthy foreign individuals in their countries.
The UK’s HMRC is one of the most sophisticated tax collection authorities in the world and the department is making significant investments in technology in the field of compliance work.
It should therefore be well placed to take advantage of new international efforts to increase tax compliance, particularly against the backdrop of the already extensive network of bilateral tax treaties in the UK, and not forgetting that the UK was a founding member of the OECD’s Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC) forum.
This article discusses the main developments in support of the increased focus on international transparency and tax compliance in the UK. There are other international fiscal initiatives, particularly in the field of corporate taxation, but such initiatives are beyond the scope of this article.
Read More