Zoe is an experienced corporate and commercial Tax & Structuring partner based in our London office. Over the last twenty years, Zoe has developed specialist expertise in tax advice, structuring, implementation and ongoing risk management for a wide variety of UK and international clients, transactions and projects. 

In addition to core transactional work, Zoe's advisory practice covers an extensive range of topics including; complex tax issues on UK and cross-border restructures, reorganisations and refinancing; inward investment; international movement and repatriation of capital; tax relating to employment, pensions and management incentive structures; banking and finance; tax risk management projects (e.g. IR35 and the Criminal Finances Act); demerger structuring advice; and fund structuring advice. 

Zoe has particular expertise in private equity, equity capital markets and private and listed funds. Her management incentives practice covers the full range of tax advantaged and non-tax advantaged incentives and remuneration structures, whether individual, select group or all-employee plans including EMI, CSOP, SAYE, SIP, LTIPs, carried interest and co-investment arrangements. She is accustomed to working with specialists in other jurisdictions to structure arrangements for use by multinational management teams and employee bases. 

Zoe is a solicitor advocate with fifteen years' experience taking leading roles in tax disputes, including cases in which she has successfully acted as leading advocate before the Tax Tribunal.

  • Tax structuring advice for a US based private equity house in connection with a cross-border M&A transaction involving CGT rollover issues for structures using LLCs and interaction with US permanent establishment and tax residence rules 
  • Demerger structuring advice for an international group of companies headquartered in North America, including consideration of all four standard demerger types and devising an alternative structure to meet specific client needs 
  • Pre-listing tax advice and structuring for EMI, CSOP, LTIP and carried interest plans. 
  • Fund structuring advice prior to listing, including the application to HMRC for investment trust status 
  • Withholding tax and procedural advice and documentation in connection with a complex suite of mezzanine facilities 
  • Leading and managing a long term IR35 project for a major construction group which has 10,000 contractors of many different types. Working with commercial, tax, finance, HR, legal and compliance functions to carry out detailed risk assessments, develop a contracting policy and produce a suite of documents for use across the business and its various divisions. 
  • BPP – Higher Rights of Audience - 2018
  • Warwick University MA Translation Studies – 2009 - 2010
  • University of Exeter BSc (hons) Psychology – 1994 - 1997
  • College of Law CPE and LPC – 1997-1999
  • French – excellent command
  • Spanish – basic
  • German - basic