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Sarah Bond

Partner

Tax

She is excellent. She has incredible technical knowledge, is on top of every detail and is very strategic. She is our go-to person for tax.

Chambers UK 2022

Profile details

About Sarah Bond

Sarah is based in the firm’s London office and her practice focuses on tax investigations and disputes, across both direct and indirect taxes.

She has extensive experience of high value, complex disputes across a variety of sectors, including in particular diverted profits tax and transfer pricing investigations. She has represented clients a number of times before the UK tax tribunals.

Sarah also has experience in advising on the tax aspects of a variety of corporate and financing transactions, including mergers and acquisitions, tax structured finance transactions and restructurings, both domestic and cross-border.

Recent work

  • Advising Gallaher Limited on a dispute concerning whether the tax treatment of a cross-border intra-group asset transfer is in breach of EU law, which is currently on appeal to the Upper Tribunal, with a reference made to the CJEU for a preliminary ruling. 
  • Advising various groups on disputes relating to the corporation tax treatment of their UK financing arrangements, including “unallowable purpose” and thin capitalisation challenges.
  • Advising various multinational clients on complex, high value disputes relating to transfer pricing, diverted profits tax (DPT), controlled foreign company (CFC) and permanent establishment risk.
  • Advising on petroleum revenue tax and capital allowances enquiries and disputes in the energy sector.
  • Advising Glencore on its dispute with HMRC in respect of diverted profits tax. 
  • Advising Tesco on a dispute with HMRC regarding the VAT treatment of Tesco’s Clubcard scheme, which the Upper Tribunal decided in favour of Tesco in January 2019 (and is not being appealed by HMRC).
  • Advising large corporates on tax-related contractual disputes.

Qualifications

  • Solicitor, England and Wales, 2007
  • Legal Practice Course - BPP Law School, 2005
  • LLB, Jurisprudence - Balliol College, Oxford University, 2004