Zoe has an extensive experience in supply chain structuring and the international aspects of mergers, acquisitions, disposals, corporate restructuring and investment funds. 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 Entrepreneurial Tax Associate Director and also 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 advised:

  • a European hedge fund with £1bn under management on the tax implications and risks arising from secondary market debt and equity acquisitions, including structuring, treaty interpretation, U.S. portfolio interest exemption analysis and origination risks;
  • on the tax considerations of establishing Luxembourg fund investing in UK real estate, including fund vehicle and structure, holding structure, location of SPVs, availability of Luxembourg/UK double tax treaty and impact of ever changing UK taxation of real property;
  • a $1bn+ U.S. Quant Fund with offices in the Netherlands on its UK permanent establishment and Diverted Profits Tax risk through use of severs at the London Stock Exchange;
  • on the first independent power project in Nigeria including the ownership and investment structure for the founders, financing structure for investors and extraction of development and success fees;
  • 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; and
  • advised a non-UK property developer in respect of an enquiry raised by HMRC’s Offshore Property Developers Task Force on a £500bn UK property transaction.

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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