Speaker details

Biography

Heather handles all aspects of business taxation and is engaged in tax planning and dispute resolution. Heather has 30 years' experience in handling tax matters on behalf of clients in the retail, manufacturing, shipping, energy, telecoms, financial and insurance sectors. Heather is a Solicitor Advocate with rights of audience in all of the UK Courts including the Supreme Court and is an Accredited Mediator with the Centre for Effective Dispute Resolution. Heather is also a Judge in the First Tier Tribunal (Tax Chamber) in England. Heather's experience includes: • BMBF v Mawson 2004 advising Bord Gais Eireann the lessee in the ground breaking decision of the House of Lords establishing the purposive construction of taxing legislation • British Aggregates Association on the correct test to apply to determine whether the operation of the aggregates levy involves unlawful State aid, with success in the European Court of Justice (ECJ) in 2008 and 2012. In 2013 the Commission issued a preliminary decision that some exemptions were unlawful aid • Garrett Curran v HMRC 2012: successful defence in the First tier Tribunal that interest paid early and discounted for early receipt is still interest and an agreement which spreads forward the taxpayer’s relief is binding on HMRC • Prudential v Pandolfo (Inspector of Taxes): the highly publicised case on the availability of legal privilege to advice given by non-legal tax advisers, acting for the Law Society on its successful intervention in the Court of Appeal and proceedings in the Supreme Court in November 2012 • Sun Life of Canada (UK) Limited v HMRC: a dispute over the availability of losses of £625 million, requiring close analysis of the technical life assurance tax regime, with final success in the Court of Appeal in 2010 • a large international financial group on a dispute relating to deductibility of interest (including transfer pricing issues)