Emma specialises in tax, advising on direct and indirect tax arising on corporate transactions, including: deal structuring and tax driven restructuring; negotiating tax covenants, warranties and disclosures on company sales and acquisitions; and VAT TOGC and SDLT on business transfers.
Emma’s understanding of tax interaction means she is ideally placed to act for corporate clients and their expansion.
In addition, Emma advises on the implementation of incentive schemes, including: EMI options; unapproved options; CSOPs; SIPs; EBTs; and transfer to Employee Ownership assisting clients retain and incentivize key employees.
Emma’s advisory work includes succession planning, asset protection and advice for HNW individuals, particularly those with international interests.
Having represented the taxpayer in HMRC enquiries and disputes including in the First-tier Tax Tribunal, Emma has experience in how HMRC operates. This gives Emma valuable insight into how to effectively complete necessary reporting to HMRC and to mitigate any areas of perceived risk.
Jurisdiction: England & Wales
- Advising the shareholders of a vehicle leasing company, its associated fleet management company and LLP (of which both companies were members) on the sale thereof and simultaneous investment by a leading investment firm and reinvestment by the continuing shareholders for £35m.
- Advising on the cross-border demerger of a trade to divide the business of a company between UK based founder shareholders and an exiting shareholder in France. Preparing the tax clearance application and advising on the potential UK tax exposure.
- Advising a global company operating in data intelligence in relation to a global share option scheme to incentivise and retain key individuals (employees, NEDs and consultants) in the UK and the US. Working with a US law firm in relation to tax advantaged schemes in the US.
- Advising an NHS Consultant born in Jordan who had lived in the UK since arriving in the UK to take A-levels as to his non-UK domiciled status. Working closely with his accountants to prepare a detailed disclosure to HMRC as he had made remittances to the UK that remained undeclared. A property in Jordan had recently been sold for £2m, the client was due to retire and wanted to be certain as to his tax compliance. Successfully negotiating a penalty free settlement with HMRC.
- Representing a Pension Scheme Administrator in a long running dispute with HMRC in the First-tier Tax Tribunal in connection with lead appeals concerning transactions entered into by the schemes using intellectual property assets as security for loans or as assets purchased by the schemes and leased back where the valuation of the underlying asset is disputed.