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).
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. She is a member of the RBA. 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.
Jensal Software Ltd v HMRC (TC/2017/00667)
Georgia was instructed in this IR35 case for the Revenue, at which it was argued that the hypothetical contract between a consultant and the DWP would have been one of employment and thus caught by the IR35 legislation. The case was in the Usetech line of cases; i.e. with the interposition of both a personal services company and a recruitment agency. The hearing took place in October 2018. Judgment is awaited.
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. At a PH in July 2016, the status of the BBC, as an interested party was determined ( UKFTT660 (TC)). On 13 March 2017 the taxpayers made an application for specific disclosure, in which Georgia appeared against Adam Tolley QC. The application was allowed in part. The substantive case is due to be heard in April and May 2018.
Taxation of Employees
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.
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 banks, rail companies, and some well-known brands) and the public side, regularly appearing for the Government Legal Department 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).
Some recent cases include:-
Employment Status and Vicarious Liability
Breach of Contract
Unfair Dismissal and Whistleblowing
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)