Zoe has an extensive knowledge of international tax systems and a special interest in double tax treaty interpretation, extraction and exploitation of IP and the role of EU law in tax matters. Zoe is fascinated with the changing tax landscape and the issue of tax laws not keeping up with new and unprecedented ways businesses operate through changes in supply chain to creation of innovative and complex IP. In particular the role of adviser in navigating this field and identifying appropriate tax risk management policies.

After starting her career at Milestone in 2006, Zoe moved to Grant Thornton where she was Associate Director and Head of Tax for the China Britain Services Group. Zoe is a member of the Association of Taxation Technicians and an Affiliate of the Chartered Institute of Tax, having completed the Advanced Diploma in International Taxation. Zoe was the author of Tolley’s International Tax Planning for 2015- 2017 before passing the baton.

Most recently, Zoe has:

  • worked as trusted adviser to a high-profile international architectural practice with operations in the UK, Germany, Italy, and China, providing wide ranging advice, including:
    • restructuring the operating entities to facilitate a tax efficient transfer of shares;
    • introduction of a centralised group cost centre for greater transparency and sharing of costs across the group entities;
    • extraction of a property from a German property partnership ensuring reliefs available under UK and German law for the UK resident partners;
    • providing UK and German inheritance tax advice to secure access to reliefs particularly in light of no spousal exemption under German law; and
    • a risk review of the group holding company, covering permanent establishment risk in Germany, Italy and Spain and deductibility of expenses;
  • advised a number of U.S. headquartered firms with sales and marketing operations in the UK on how to structure customer contracting models and activities of the UK personnel to assess permanent establishment risk, as well as the impact of the Diverted Profits Tax;
  • advised a non-UK property developer in respect of an enquiry raised by HMRC’s Offshore Property Developers Task Force; and
  • advised a U.S. Quant Fund with offices in the Netherlands on its UK PE and DPT risk through use of severs at the London Stock Exchange.

Zoe's latest Article

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Are HMRC’s 281 Million Pounds DPT Tax Yield Stats Misleading the Public? – 5 October 2017

The U.K.’s tax authority HM Revenue & Customs (“HMRC”) recently published statistics setting out a 281 million pounds tax yield in 2016–17 from the Diverted Profits Tax. In question was the so-called “Google Tax” introduced in April 2015 as the answer to counter perceived tax-avoidance by large multinational groups that generate significant revenue from U.K. customers but seemingly pay little U.K. corporation tax by comparison.

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