Georgina Pein

Tax & Customs

Georgina is developing a busy practice across all areas of revenue and customs law. During pupillage she was supervised by Edward Waldegrave and gained exposure to a wide variety of tax matters in the First-tier Tribunal, the Upper Tribunal and the Court of Appeal. Georgina recently undertook a three-month part-time secondment with HMRC.

Current and recent highlights in this field include:

• Proceedings before the First-tier Tribunal concerning the entitlement of taxpayers to incorporation relief (acting for HMRC, led by Edward Waldegrave).
• Part 8 rectification proceedings brought by a taxpayer company (acting for HMRC, led by Edward Waldegrave and Colm Kelly).
• Property 118 and Cotswold Barristers Limited v HMRC TC/2024/01972: appeal before the First-tier Tribunal concerning the allocation of “scheme reference numbers” under section 311 of the Finance Act 2004 (as a pupil).
• R (Taxpayer) v HMRC: drafting a statement of reasons to the Court of Appeal resisting a challenge by the taxpayer to a case-management decision of the High Court. The High Court ordered a stay of the judicial review proceedings due to concurrent proceedings in the First-tier Tribunal with overlapping legitimate expectation arguments (as a pupil).
• R (Taxpayer) v HMRC: drafting summary grounds in relation to judicial review proceedings challenging HMRC’s decision to disclose taxpayer information to foreign authorities (as a pupil).
• Advice on the application of section 36 of the Taxes Management Act 1970 (as a pupil).