Photo, Naoko Uehara

Naoko Uehara

Counsel
Baker & McKenzie Services Limited

Biography

Naoko Uehara is a counsel in Baker McKenzie’s London tax disputes team, with significant experience advising multinational clients through high-value and complex HMRC enquiries, appeals through the Tax Tribunals, Court of Appeal and the Supreme Court, and judicial review proceedings. Her practice spans both direct and indirect tax disputes, including transfer pricing, unallowable purpose, diverted profits tax, VAT, employee benefits and customs.

Naoko has acted for clients across a broad range of industries including technology, financial services, telecommunications, insurance, pharmaceuticals and consumer-facing platform businesses. She has been recognised by Chambers as an “Associate to Watch” and was also named a 2025 Law.com “Female Rising Star”, reflecting her growing profile in major tax appeals and her contribution to diversity in the UK legal industry.

Representative Legal Matters

  • Represented Prudential in a case concerning the VAT treatment of investment management services, with proceedings before the First-tier Tribunal, Upper Tribunal, Court of Appeal and the Supreme Court.
  • Represented the Kwik-Fit Group in landmark litigation concerning the application of the UK unallowable purpose rules, with proceedings before the First-tier Tribunal, Upper Tribunal and Court of Appeal.
  • 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 Refinitiv 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.
  • Eastern Power Networks Plc and others v HMRC [2017] UKFTT 494 (TC) in a successful application for a closure notice despite outstanding schedule 36 information requests.

Professional Associations and Memberships

  • Law Society of England and Wales - Member

Admissions

  • England & Wales~United Kingdom (2016)

Education

  • BPP (LPC) (2014)
  • University of Law (GDL) (2012)
  • University of Birmingham (BA Hons) (2011)

Languages

  • English