One minute with Veronica McMahon, Head of Advisory Knowledge at Osborne Clarke.
What’s keeping you busy at work?
As a knowledge lawyer, there’s always plenty to keep me busy – from delivering training, keeping the team up to date with technical developments, sharing knowhow, creating client content and wider project work around Generative AI, with recent domestic and international developments also keeping me occupied!
What do you know now that you wish you’d known at the start of your career?
To have an open mind for the type of law that you may want to practice and to embrace opportunities. Thinking that I wanted to be an employment lawyer when I first started out, I was disappointed not to have been given employment as my optional seat as a trainee, getting tax instead. Thank goodness my attempt to swap seats was unsuccessful as I found an area of law which I knew would challenge me, one I’d never find boring, and I’ve been rewarded with a stimulating and varied career (and I still enjoy dabbling in employment tax).
Are any new rules causing a particular problem in practice?
The Pillar Two rules are causing difficulties for tax advisers on M&A transactions and also present a challenge for knowledge lawyers with regards to the impact on our standard tax documentation on deals. The rules are complex, cannot necessarily be diligenced and where both parties to a transaction are in scope there may not be a clearcut answer as to who should bear liability in all cases. Where Pillar Two is or might be relevant, the parties need to work out what Pillar Two adjustments may be applicable and consider what contractual protections, limitations and conduct rights might be needed in the documentation. It will be interesting to see how the tax insurance market develops as regards any Pillar Two risk.
Has a recent tax case caught your eye?
The Syngenta case ([2024] UKFTT 998 (TC)), the latest in a series of unallowable purpose cases, reinforces the themes from the BlackRock, Kwik-Fit and JTI cases and HMRC’s updated guidance. It was, however, interesting to see the level of detail into which the tribunal delved on the documentation and the comments it made about the credibility and authenticity of certain documents when viewed in the round.
How has the world of tax knowhow and training evolved over the years?
There have been massive developments in tax knowhow and training since I have been in practice. Firstly, the volume of resources that is now online is hugely helpful, although it always helps to have hard copies of the yellow and orange tax handbooks available! Training has developed with the advent of online platforms such as Teams which, although a huge benefit during Covid, has led to some challenges post-Covid where hybrid training is often the norm. The advent of document automation has also been game changing, with hours of time manually amending precedents being saved and the rise of Generative AI tools also changing how we work. Although with the advent of GenAI, lawyers will learn additional tools to help with work, I suspect that training will become even more important to ensure that our lawyers still develop key skills such as analysis, problem solving and critical thinking.
You might not know this about me but...
I was a keen ice skater in my youth and I had hoped my children might follow in my footsteps, but they were more interested in ice hockey and I now manage the Haringey Hounds Girls ice hockey team at Alexandra Palace. It’s a beautiful (if cold!) place to spend the weekends.
One minute with Veronica McMahon, Head of Advisory Knowledge at Osborne Clarke.
What’s keeping you busy at work?
As a knowledge lawyer, there’s always plenty to keep me busy – from delivering training, keeping the team up to date with technical developments, sharing knowhow, creating client content and wider project work around Generative AI, with recent domestic and international developments also keeping me occupied!
What do you know now that you wish you’d known at the start of your career?
To have an open mind for the type of law that you may want to practice and to embrace opportunities. Thinking that I wanted to be an employment lawyer when I first started out, I was disappointed not to have been given employment as my optional seat as a trainee, getting tax instead. Thank goodness my attempt to swap seats was unsuccessful as I found an area of law which I knew would challenge me, one I’d never find boring, and I’ve been rewarded with a stimulating and varied career (and I still enjoy dabbling in employment tax).
Are any new rules causing a particular problem in practice?
The Pillar Two rules are causing difficulties for tax advisers on M&A transactions and also present a challenge for knowledge lawyers with regards to the impact on our standard tax documentation on deals. The rules are complex, cannot necessarily be diligenced and where both parties to a transaction are in scope there may not be a clearcut answer as to who should bear liability in all cases. Where Pillar Two is or might be relevant, the parties need to work out what Pillar Two adjustments may be applicable and consider what contractual protections, limitations and conduct rights might be needed in the documentation. It will be interesting to see how the tax insurance market develops as regards any Pillar Two risk.
Has a recent tax case caught your eye?
The Syngenta case ([2024] UKFTT 998 (TC)), the latest in a series of unallowable purpose cases, reinforces the themes from the BlackRock, Kwik-Fit and JTI cases and HMRC’s updated guidance. It was, however, interesting to see the level of detail into which the tribunal delved on the documentation and the comments it made about the credibility and authenticity of certain documents when viewed in the round.
How has the world of tax knowhow and training evolved over the years?
There have been massive developments in tax knowhow and training since I have been in practice. Firstly, the volume of resources that is now online is hugely helpful, although it always helps to have hard copies of the yellow and orange tax handbooks available! Training has developed with the advent of online platforms such as Teams which, although a huge benefit during Covid, has led to some challenges post-Covid where hybrid training is often the norm. The advent of document automation has also been game changing, with hours of time manually amending precedents being saved and the rise of Generative AI tools also changing how we work. Although with the advent of GenAI, lawyers will learn additional tools to help with work, I suspect that training will become even more important to ensure that our lawyers still develop key skills such as analysis, problem solving and critical thinking.
You might not know this about me but...
I was a keen ice skater in my youth and I had hoped my children might follow in my footsteps, but they were more interested in ice hockey and I now manage the Haringey Hounds Girls ice hockey team at Alexandra Palace. It’s a beautiful (if cold!) place to spend the weekends.
