Jessica Eden

Jessica concentrates her practice on corporate and international tax disputes. She advises on large-scale, complex enquiries, including within HMRC's High Risk Corporates Program. In addition to utilising ADR techniques to reach negotiated resolution with HMRC, Jessica act for clients in the Tax Tribunal and Appeal Courts at every level. She has experience defending clients' public law rights through Judicial Review claims in the Administrative Court and defending claims to legal professional privilege in the FTT. She also supports clients with dispute readiness, including preparation of legal defence files and dawn raid training. Jessica regularly acts for large multinationals in resolving transfer pricing and Diverted Profits Tax disputes and advises clients on debt financing enquiries.

• Kwik Fit Group Ltd & Others v HMRC at the First-tier (Tax) Tribunal [2021] TC08226 and Upper Tribunal [2022] UKUT 00314 (TCC) on the application of the unallowable purpose rules.
• Refinitiv UK Holdings Ltd and Another v HMRC [2023] UKFTT 222 (TC) in successfully defending claims to legal advice privilege.
• R (on the application of Refintiiv Ltd) v HMRC [2023] UKUT 187 in an interlocutory application for disclosure in Judicial Review proceedings.
• R (on the application of Refinitiv Ltd & Others) v HMRC [2023] UKUT 257 (TCC) in a Judicial Review claim in respect of Diverted Profits Tax notices.
• The Medical Defence Union Ltd v HMRC [2021] UKUT 249 in a successful appeal confirming returns of insurance premium were not taxable under the principle of mutuality.
• Eastern Power Networks Plc and others v HMRC [2017] UKFTT 494 (TC) on a successful application for a closure notice despite outstanding schedule 36 information requests.

• Highly Regarded Practitioner & Woman in Tax Leader, International Tax Review Tax Controversy 2024
• Band 3, UK Tax Contentious, Chambers & Partners, 2024
• Tax Dispute Resolution Lawyer of the Year, Women in Business Law Awards, 2021

• CEDR Accredited Mediator