Expertise
Rachel is a Senior Tax Manager in Addleshaw Goddard’s Tax Disputes and Investigations practice. Rachel is a member of The Association of Taxation Technicians with 13 years of experience in advising clients on a wide range of taxes having joined McGrigors in 2011.
Rachel acts for both large corporates and HNWI individuals and has extensive experience in handling potential disputes, resolution of complex disputes with HMRC on indirect taxes, direct taxes, property taxes (SDLT, VAT & CIS), employment tax and high net worth individual tax issues.
McGrigors and Pinsent Masons merged in 2012 and Rachel worked on tax advice and litigation out of Manchester.
- Experience
Rachel’s experience includes:
- Assisting a Multinational Construction Company (Large Business) with an investigation centred around the Corporate Criminal Office, managing the forensic investigation of the company’s records to establish how certain errors relating to VAT (and employment status) had arisen. Once established we assisted the company in making a suitable disclosure to HMRC and with rectifying its internal procedures.
- Acting for Dalriada Pensions Trustees following their appointment by The Insolvency Service on two pension funds which owed the leasehold to a large number of storage pods located throughout the UK. The issue arose as to whether, for VAT purposes, the pension schemes were letting temporary storage facilities or instead exploiting some other property interest.
- Providing strategic advice to clients on the changes to IR35 rules and how businesses should structure the off-payroll workforce to effectively manage to the risks associated with IR35 and its compliance obligations are met.
- Acting for the Company Chemist Association and a group of its members (all Large Business Retailers) regarding “how” HMRC have conducted their enquiries around the tax status of locum pharmacists.
- Advising various UHNWI, including several members of the Royal Family in Qatar, on HMRC’s enquiries into their UK residency position and agreeing with HMRC that the individuals were treaty non-resident for a period of 6 years.
- Advising various newly incorporated UK subsidiaries of non-UK parent companies in respect of their various UK tax compliance obligations and responsibilities in the UK.
- Advising a large North American energy infrastructure company in respect of its historic ownership of a UK headquartered company specialising in global commodities, warehousing and logistics. The UK commodities company was subject to a HMRC enquiry in respect of the tax residence of its various subsidiaries located in Singapore, Netherlands and the US. Our work involved an extensive investigation, document review and conducting witness interviews to satisfy HMRC that the tax residence of the subsidiaries were in the jurisdiction of incorporation and not the UK. We were successful in challenging HMRC’s attempt to raise assessments going back 20 years for negligence therefore substantially limiting the tax years under enquiry.
- Professional Memberships
- Association of Taxation Technicians