Fiona has over 30 years’ experience of handling and resolving complex commercial and tax disputes. From 2009 to 2015 she focused exclusively on tax litigation as a partner and head of corporate tax disputes at Deloitte LLP. Prior to this Fiona had a broad commercial disputes practice including civil fraud, banking and finance litigation, shareholder and partnership disputes, and professional negligence. She now enjoys a mix of work across the commercial and tax disputes spectrum.
The legal directories have reported that Fiona’s “combination of tax knowledge and prowess in litigation is really compelling”. She is said to have “a superb grasp of litigation and tactics” and has been described as “clever and organised”, “quick and sharp” and “a cut above the rest”. Opponents have been reported as “championing her straight-talking and pragmatic approach to negotiation”.
Fiona has a law degree from Cambridge University. She worked at Withers and Theodore Goddard before moving in 1996 to the Arthur Andersen law firm, Garretts, to form a new litigation group for them, and was promoted to partner in 1998. It was at Garretts that Fiona began to work on tax disputes.
Following the demise of Arthur Andersen, Fiona moved as a partner to Reynolds Porter Chamberlain where she became head of their commercial litigation group and set up a tax disputes practice for them.
In 2009 the opportunity arose for Fiona to join one of her major clients, Deloitte LLP, as a partner and head of corporate tax disputes where she remained until joining Enyo in 2016.
Representative cases:
- West Burton Property Limited -v- The Commissioners for HM Revenue and Customs [2021] UKFTT 160 (TC)
Acting for a subsidiary company of EDF Plc in a claim concerning the accounting treatment of GBP65 million of Deferred Revenue Expenditure
- (1) Urenco Chemplants Limited and (2) Urenco UK Limited -v- The Commissioners for HM Revenue and Customs [2022] UKUT 00022 (TCC)
Representing Urenco Plc in a claim for capital allowances in relation to expenditure of approximately GBP192 million on a substantial nuclear deconversion facility in Cheshire
- Northern Gas Networks Limited -v- The Commissioners for HM Revenue and Customs [2021] UKUT 0157 (TCC)
Claim on behalf of Northern Gas Networks Ltd for Land Remediation Relief in relation to GBP110 million of expenditure on the repair and replacement of iron gas pipes.
- (1) Cheshire Cavity Storage 1 Limited and (2) EDF Energy (Gas Storage Hole House) Limited -v- The Commissioners for HM Revenue and Customs [2021] UKUT 0050 (TCC)
Acting for a subsidiary company of EDF Plc in a claim for capital allowances in relation to expenditure on the creation of underground gas storage cavities.
- Patrick Degorce -v- HMRC [2017] EWCA Civ 1427
Defending Patrick Degorce against the disallowance by HMRC of expenditure incurred by him in relation to his involvement in film schemes
- TDS and Ladbrokes Group -v- HMRC [2018] EWCA Civ 549
Acting for the Appellants in relation to issues concerning debts under a loan relationship and whether or not they were allowable under FA 1996 Schedule 9
- (1) Barclays Wealth Trustees (Jersey) Limited and (2) Michael Dreelan -v- HMRC [2017] EWCA Civ 1512
Acting for the Appellants in relation to issues concerning the status of property within a Jersey-resident discretionary trust and whether or not it was excluded property not subject to the periodic charge.
- Compass Contract Services -v- HMRC [2006] EWCA Civ 730
Representing the Compass Group in proceedings to establish the VAT status of the sale of cold takeaway food.
- Representation of 50+ corporate claimants between 2002 and 2015 in group litigation before the UK and European Courts relating to EU group relief, ACT, FII, cross border dividends and thin cap.
