Pembe understands the real impact decisions and investigations by HMRC can have on an individual, both professionally and personally. She uses her insight into HMRC’s decision making processes and experience advising HMRC on litigation strategy, which she obtained by working in various teams across HMRC for over a period of 6 years prior to moving to private practice. 

As a ex- HMRC litigator with over 60 appearances before the First tier Tax Tribunal she has a thorough understanding of the Tribunal process and the strain litigation can have on individuals. As a qualified Civil and Commercial Mediator, she always keen to explore alternative to going to Tribunal which includes engaging in Alternative Dispute Resolution where possible. Pembe recognises the importance of mitigating risk at the earliest stage possible.  

Pembe has strong working relationships with well regarded Barristers on the Tax circuit and is always willing to work collaboratively to get the best result possible.

Further, whilst defending HMRC, Pembe was involved in direct and indirect tax litigation including;

Tax avoidance schemes, Employment related taxation, Residence and Domicile, IR35, Best Judgement VAT assessments, Personal Liability Notices, Behavioural Penalty Assessments, late filing of VAT penalties, refused VAT expense/repayment claims, ATED, classification of a supply and VAT relief under the Construction Industry Scheme.

In the past she has achieved the following for her clients;

  • Advised HMRC officers on the legality of decisions and sought agreement for withdrawal.
  • She was involved in the upskilling of HMRC officers on investigations surrounding disclosure applications under the Promoters of Tax Avoidance Scheme (POTAS) Rules.
  • Advised HMRC lawyers and drafted internal guidance on Judicial review as the Judicial Review lead for the Solicitors Office, HMRC.
  • Delivered training to investigating officers in Counter Avoidance in support of disclosure of tax avoidance schemes.
  • Worked on complex direct tax appeals with Junior and Kings Counsel.
  • Successfully defended the first challenge against the Making Tax Digital Requirements
  • Successfully defended a challenge against HMRCs conduct before the Upper Tribunal and over 60 challenges before the First-tier Tribunal.

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