All shapes and sizes of tax dispute. I still enjoy client work as much as ever, with no two cases the same. My portfolio spans private clients, trustees, corporates and estates, ranging from voluntary disclosures to serious tax fraud investigations. I particularly enjoy working alongside barristers, crime lawyers, family offices and trustees.
What do you know now that you wish you’d known at the start of your career?
Sound judgement and strong investigative skills are valuable career skills for any tax practitioner. Judge people by what they do rather than what they say, particularly when you’re not in the room. Avoid assumptions, listen to the other side and seek to understand motivations. And reject any behaviour that devalues women in all areas of your working life, even when it’s disguised as humour, habit or frustration.
If you could make one change to a tax law or practice, what would it be?
I would improve access to debt management support for taxpayers, particularly owner-managed businesses and individuals facing genuine financial difficulty. Tax debt can be overwhelming for people who want to comply but have fallen on hard times.
This is one reason I have long supported TaxAid and recently became an ambassador for the charity. More well-trained and properly resourced HMRC debt management teams could make a significant difference to the general public’s experience of tax.
Alongside that (sorry, that’s two changes!), I would introduce a more accessible and widely available disclosure facility for businesses and individuals. Voluntary disclosure is one of the cornerstones of an effective tax system, and taxpayers who want to put things right should be able to do so with confidence and support. And then have time to pay via HMRC Debt Management.
Has a recent tax case caught your eye?
Yes – Quillan v HMRC [2026] UKUT 300 (TCC), as an Upper Tribunal ruling, provides useful precedent. The decision confirms that there is no single formal process for writing off a loan for tax purposes, and it provides valuable guidance on the evidence that may demonstrate a loan has in fact been released. Advisers should bear the case in mind when documenting loan write-offs and maintaining company records.
Are there any new tax rules causing a particular problem in practice?
Not a new rule, but a new domicile case – Griffin v HMRC [2026] UKFTT 1319 (TC) – highlights a broader problem. Certain areas of tax are so fact-specific that disputes and litigation become the only route to obtaining certainty. We saw this previously with the old residence rules, then IR35 and now under aspects of the Statutory Residence Test.
As a dispute specialist, I should perhaps welcome that, but the reality is quite the opposite. Most taxpayers involved take good professional tax advice and are genuinely trying to comply. Lengthy litigation is expensive, stressful and backlogs the tax tribunal service.
This is where simplification, advance clearances and greater access to binding rulings could make a meaningful difference, particularly in the private client arena.
You might not know this about me but...
If I wasn’t a tax adviser, I’d love to run a nail bar – polished hands and feet are important in life. Alternatively, I’d follow the family tradition and run a bakery. It could have been ‘Registers’ rather than Gail’s. I can still produce a respectable custard tart and Battenberg cake when required.
All shapes and sizes of tax dispute. I still enjoy client work as much as ever, with no two cases the same. My portfolio spans private clients, trustees, corporates and estates, ranging from voluntary disclosures to serious tax fraud investigations. I particularly enjoy working alongside barristers, crime lawyers, family offices and trustees.
What do you know now that you wish you’d known at the start of your career?
Sound judgement and strong investigative skills are valuable career skills for any tax practitioner. Judge people by what they do rather than what they say, particularly when you’re not in the room. Avoid assumptions, listen to the other side and seek to understand motivations. And reject any behaviour that devalues women in all areas of your working life, even when it’s disguised as humour, habit or frustration.
If you could make one change to a tax law or practice, what would it be?
I would improve access to debt management support for taxpayers, particularly owner-managed businesses and individuals facing genuine financial difficulty. Tax debt can be overwhelming for people who want to comply but have fallen on hard times.
This is one reason I have long supported TaxAid and recently became an ambassador for the charity. More well-trained and properly resourced HMRC debt management teams could make a significant difference to the general public’s experience of tax.
Alongside that (sorry, that’s two changes!), I would introduce a more accessible and widely available disclosure facility for businesses and individuals. Voluntary disclosure is one of the cornerstones of an effective tax system, and taxpayers who want to put things right should be able to do so with confidence and support. And then have time to pay via HMRC Debt Management.
Has a recent tax case caught your eye?
Yes – Quillan v HMRC [2026] UKUT 300 (TCC), as an Upper Tribunal ruling, provides useful precedent. The decision confirms that there is no single formal process for writing off a loan for tax purposes, and it provides valuable guidance on the evidence that may demonstrate a loan has in fact been released. Advisers should bear the case in mind when documenting loan write-offs and maintaining company records.
Are there any new tax rules causing a particular problem in practice?
Not a new rule, but a new domicile case – Griffin v HMRC [2026] UKFTT 1319 (TC) – highlights a broader problem. Certain areas of tax are so fact-specific that disputes and litigation become the only route to obtaining certainty. We saw this previously with the old residence rules, then IR35 and now under aspects of the Statutory Residence Test.
As a dispute specialist, I should perhaps welcome that, but the reality is quite the opposite. Most taxpayers involved take good professional tax advice and are genuinely trying to comply. Lengthy litigation is expensive, stressful and backlogs the tax tribunal service.
This is where simplification, advance clearances and greater access to binding rulings could make a meaningful difference, particularly in the private client arena.
You might not know this about me but...
If I wasn’t a tax adviser, I’d love to run a nail bar – polished hands and feet are important in life. Alternatively, I’d follow the family tradition and run a bakery. It could have been ‘Registers’ rather than Gail’s. I can still produce a respectable custard tart and Battenberg cake when required.
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