Georgia’s areas of practice are employment, tax, and sports law. She regularly appears in the Employment Tribunal, First-tier Tribunal (Tax Chamber), EAT and Upper Tribunal (Tax and Chancery Chamber).
Georgia is an accomplished advocate, the quality of which is reflected in the numerous prizes she has received from her Inns of Court and elsewhere, including the James Hunt prize for best advocate in her year.
In 2017 she was appointed to the Attorney General's Panel of Counsel (C Panel).
‘She is becoming a notable practitioner in tax litigation.’ - Tax: VAT, Legal 500 2019
Georgia often receives plaudits for her advocacy, eye for detail, incredible work ethic and level of preparation.
"Georgia did an amazing job in her preparation... The Judge commented on the quality and thoroughness of her written submissions and I think this was one of the factors that led to him being able to make the decision so quickly."' - Senior Associate (2016)
Georgia has a strong practice in tax litigation, regularly receiving instructions from both HMRC and the taxpayer, in First-tier Tribunal, Upper Tribunal as well as in JR cases. Her main areas of specialism are employment tax, residency and domicile - she is particularly strong in the employment / tax cross-over and the IR35 intermediaries legislation.
Kickabout Productions Limited v HMRC (TC/2017/02499)
Georgia was instructed by the taxpayer in this appeal concerning the employment status of a well-known radio presenter. HMRC argued that the presenter would have been an employee such that the IR35 legislation applied and income tax and NICs were owed on sums paid via a personal service company. As one of the first cases to consider the employment status of a radio presenter, this is likely to be a de facto leading case with wide ramifications both for those appeals stayed behind it and all presenters within the industry. Awaiting judgment.
Paya, Willcox & Allday Media v HMRC (TC/2014/03148; TC/2014/06207; TC/2016/00837)
Georgia is instructed as junior to Jonathan Peacock QC (11 New Square) and Marika Lemos (Devereux) in these appeals concerning the employment status of television journalists paid through personal services companies whilst working with the BBC. The issue is whether the personal services come within the IR35 regime. Being one of the first of many such IR35 cases concerning the entertainment industry (with a particular focus on presenters), this is being treated as a leading case, with both HMRC and taxpayers awaiting the outcome to determine how to address stayed appeals. Awaiting judgment.
Christa Ackroyd Media Ltd v HMRC (TC/2016/04992; UT/2018/0082)
Georgia has been instructed as junior to Jolyon Maugham QC in this appeal to the Upper Tribunal against the decision of the FTT ( UKFTT 0069;  S.T.I. 907), which found that the IR35 legislation applied to Ms Ackroyd’s services supplied to the BBC, such that income tax and NICs is owed. The FTT granted permission to appeal on the ‘control’ test. Ms Ackroyd seeks permission to appeal on a new point: that her services were provided under a contract directly with the BBC such that s.49(1)(b) ITEPA 2003 does not apply. This novel point would wide ramifications throughout the industry.
Taxation of Employees
Professional Game Match Officials Ltd v HMRC  UKFTT 528 (TC)
As junior to Jolyon Maugham QC, Georgia successfully represented the taxpayers in this appeal concerning the tax treatment and employment status of football referees. HMRC sought income tax and NICs in respect of referees whom it said were employed. Whilst the current appeal only concerned a group of some 40 match officials, the appeal has wider implications for referees across all tiers of English football (numbering some over 28,000 individuals). The judgment has developed the highly contentious and much-litigated ‘control’ and ‘mutuality of obligation’ tests.
Pettigrew v HMRC  UKFTT 240 (TC)
Georgia was instructed by HMRC and led by Chris Stone (Band 3) in this case concerning the tax treatment of a payment made by the MOJ to a part-time employment judge in settlement of his claim for part-time worker discrimination. After a carefully reviewing the relevant authorities, the FTT determined that the payment fell to be taxed as earnings under s.62 Income Tax (Earnings and Pensions) Act (“ITEPA”) 2003. This case has leant clarity to the taxation of discrimination damages relating to events that occurred during employment.
Tottenham Hotspur Ltd v HMRC  UKUT 453 (TCC);  4 W.L.R. 17;  S.T.C. 81;  B.T.C. 535;  S.T.I. 90
Georgia was led by Jolyon Maugham QC in this appeal before both the First-tier (Tax) Tribunal ( UKFTT 389 (TC);  SFTD 803;  STI 2499) and the Upper Tribunal ( UKUT 453 (TCC);  4 W.L.R. 17;  S.T.C. 81;  B.T.C. 535;  S.T.I. 90). The appeal concerned the tax treatment of payments made to two footballers, Peter Crouch and Wilson Palacios, on their transfer to Stoke FC. The question was whether the payments were “from employment” within the meaning of s.62 Income Tax (Earnings and Pensions) Act 2003. The judge accepted that the principle in the Court of Appeal case of Henley v Murray  1 All ER 908 applied and was binding: namely, that payments made in consideration of the abrogation of the contract were not “from” employment.
ICM (UK) Ltd v HMRC (UKUT0472 (TCC))
Georgia was instructed as junior to Akash Nawbatt QC in this Upper Tribunal (Tax and Chancery Chamber) case concerning the correct approach to tri-partite employment contracts and the territorial reach of the Construction Industry Scheme (2016).
Emerald Contracting Ltd v HMRC (TC/2015/02248)
Georgia was instructed as junior to Akash Nawbatt QC in this complex Construction Industry Scheme case that involved complex questions of the territorial scope of the scheme and the correct approach to complex contractual relationships, as well as issues concerning the employment status of individuals.
YPS Scaffolding Ltd & Ors v HMRC (TC/2015/03673, TC/2015/03675, TC/2015/03676, TC/2015/05901)
Georgia was instructed as junior Marika Lemos in this case concerning the employment status of various individuals working for a group of companies. The companies were assessed as owing significant sums in unpaid PAYE and NI contributions in respect of individuals who were asserted as being self-employed but were, on HMRC’s case, employees. The appellants’ case was struck out.
Hyrax Resourcing Limited & Ors v HMRC (TC/2017/04389; TC/2017/04408; TC/2017/04410
Georgia was instructed by HMRC as junior to Akash Nawbatt QC in this application – the first of its kind – for an order under s314A and s306A Finance Act (“FA”) 2004 that the arrangements in question were “notifiable arrangements” within the meaning of s306(1) FA 2004.
Connaught Corporate Solutions Limited v HMRC (TC/2017/05527)
Georgia was instructed by HMRC in this application for a penalty under s.100C Taxes Management Act 1970 for failing to comply with s.313C FA 2004 DOTAS information notices. Again, this is the first application of its kind. The notices were issued following Channel 4 Dispatches programme, ‘How the Rich Avoid Tax’ but the taxpayers refused to comply. A test case for HMRC, the judgment will shed light on the status of such notices.
Judicial Review (Tax)
R (Glencore) v HMRC  EWCA Civ 1716;  BTC 32
Georgia was instructed by HMRC as junior to Timothy Brennan QC in this first case concerning diverted profits tax, a new tax introduced by the Finance Act 2015. The taxpayer sought judicial review of HMRC’s decision to issue it with a charging notice under s.95 Finance Act 2015. The Court of Appeal held that judicial review was not appropriate where alternative remedies within the statutory scheme existed. The case is an important authority on the applicability of judicial review in the tax context
Residency / Domicile
Georgia is regularly instructed in domicile and residency cases, including the following:
S v HMRC (2016-2017)
Georgia has been instructed by HMRC as junior to Akash Nawbatt QC in this domicile case to determine the domicile of an individual with a complex domicile history. The FTT hearing has been listed for 2017.
R v HMRC (2014-2016)
Georgia was instructed by HMRC as junior to Chris Stone and Akash Nawbatt QC in this domicile case. The taxpayer was a high net worth individual, seeking to prove that he had displaced his UK domicile of origin. After years of dispute, the taxpayer eventually conceded.
Clipper Group Holdings Ltd v HMRC (TC/2012/03394)
Instructed by HMRC and led by Jonathan Hall QC in this high value case concerning unpaid Customs and Excise duty on illegally diverted consignments of alcohol. The Appellant argued that the assessment was unreasonable and disproportionate as they were not a party to the fraud. HMRC relied on reg.5 of the Excise Goods (Accompanying Documents) Regulations 2002 and Butlers Ship Stores and successfully resisted their application for wide-ranging specific disclosure at a preliminary hearing. The appeal was withdrawn in January 2016.
I Ltd v HMRC
Whilst under investigation by HMRC, the taxpayer sought repayment of VAT from HMRC. Georgia gave advice to a taxpayer on a novel JR point; namely, that it could be used to review the lawfulness of a failure to act in the exercise of a public function.
Georgia has a strong and diverse practice in employment law. She has significant experience representing clients in Employment Tribunals, including multiple-day hearings in whistleblowing and discrimination claims, as well as in the EAT. Georgia represents both claimants and respondents from both the private side (including some well-known brands) and the public side, regularly appearing for the Treasury Solicitors and the Metropolitan Police. In addition to her advocacy work, Georgia also has extensive advisory experience, developing a particular specialism in employment status– an area in which her experience in the tax field is invaluable.
Georgia assisted with the most recent edition of Discrimination Law (Bloomsbury Professional), contributing to chapters on Discrimination in Education, Discrimination in the Provision of Goods and Services, Discrimination in the Provision of Premises and Housing, Discrimination in Clubs and Associations, and Exemptions. She is appointed to the Attorney General's Panel of Counsel (C Panel).
Tribunal cases include:-
Discrimination and Harassment
Breach of Contract
Unlawful Deduction of Wages and Human Trafficking
Redundancy and Unfair Dismissal
Georgia is forging a practice in sports law and accepts instructions in all aspects, including taxation, disciplinary matters, discrimination, employment, personal injury, and contractual disputes. She has led cases in her own right, including advising a firm of solicitors on how to issue proceedings abroad against a footballer, based in the Netherlands, now playing for a Russian club. Recently, as a junior to Jolyon Maugham QC she represented Tottenham Hotspur Ltd in a case against HMRC, concerning the transfer of players.
ELA, FRU, ELBA, COMBAR, RBA, PNBA, PIBA, IFS
James Hunt Scholar (Advocacy) - Gray’s Inn
Ede and Ravenscroft Scholar (Advocacy) - Gray’s Inn
Birkenhead Scholar (Academic) - Gray’s Inn
David Karmel Scholar (Academic) - Gray’s Inn
The Norman Tapp Memorial Prize for Excellence in Mooting - Gray’s Inn
LawWorks & Attorney General Student Award, Best New Student Pro Bono Activity for Vocalise
Appointed to the Attorney General's Panel of Counsel (C Panel) in 2017
University of Oxford, BA (Hons) English Language and Literature (First Class)
City University GDL (Distinction)
City University London BPTC (Very Competent)