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Tax Director

Heather has over 13 years’ experience assisting private clients build and retain their wealth whilst also protecting clients from HMRC tax enquiries and investigations. In the current quickly changing environment it is important that tax planning is both robust and defensible whilst ensuring that any existing planning still meets its intended purpose and the prevailing UK legislation.

Notable examples of recent cases that Heather has handled include:


Tax enquiries / COP8 investigation – Tax Avoidance:

  • settlement of tax disputes concerning substantial claims for loss relief for a production film partnership settled with HMRC with 80% of tax relief being allowed
  • tax investigation in relation to business property renovation allowance claims for a property investment fund
  • settlement of tax investigation in relation to capital allowance claims in respect of enterprise zones settled with 20% tax relief being allowed

Tax enquiries / COP8 investigation – General Tax Planning:

  • S9A tax enquiry in relation to the residence and domicile status of a high profile individual
  • COP8 tax investigation in relation to disposal of a stately home
  • COP8 tax investigation in relation to a property development for a sports personality reducing the tax determined from £1.8m to just over £10k
  • COP8 tax investigation in respect of the use and disposal of a super yacht

Voluntary Disclosures:

  • disclosure under the Liechtenstein Disclosure Facility successfully agreed an alternative methodology rather than utilising RPI resulting in a saving of £300k of tax
  • disclosure under the Worldwide Disclosure Facility negotiated and agreed with proposed approach and also HMRC stipulated that no penalties will be at issue
  • disclosure under the Digital Disclosure Facility successfully agreed based solely upon written submission and agreed with no penalties, resulting in a saving of £80k.
  • voluntary disclosure – successfully negotiated limiting the period of assessment to 4 years and agreed upon an approach with no penalties becoming due

Accelerated Payment Notices:

  • numerous significant Time to Pay arrangements negotiated and agreed with HMRC in particular an arrangement agreed for over 39 months