Sarah Blakelock

International Tax at INDEPENDENT EXPERT

Speaker

Sarah Blakelock is an Independent Consultant, Arbitrator and Mediator with a specific focus on the resolution of corporate tax, transfer pricing and international tax disputes. As an international tax advisor, Sarah consults to multi-national enterprises, intergovernmental organisations, individual countries, and most recently with Slaughter and May and Deloitte in London on international tax issues, tax administration and the resolution of complex cross-border tax disputes. Sarah has a wealth of experience in advising MNEs and corporate taxpayers concerning complex and high value corporate, transfer pricing and international tax issues and in respect of tax investigations and disputes. She is often called in by taxpayers to provide guidance in specific fiscal authority engagement strategy and negotiation, issues of evidence and proof and managing complex cross-border and international tax disputation. She is briefed by corporates and MNEs to plan, prepare and review documentation and information to support tax positions, prepare witness evidence, brief expert witnesses, and liaise with external advisors and counsel. Sarah also advises individual countries and inter-governmental organisations in tax policy development and implementation. Sarah has most recently advised MNEs and OECD and Inclusive Framework member countries in respect of OECD's Digitalisation of the Economy project, digital services taxes, treaty and domestic General anti-avoidance/abuse rules, tax administration, ICAP, APAs, mutual agreement procedure and arbitration in international tax. Working with supra- national organisations, Sarah assists developing countries to review their domestic tax regimes to identify and assist with the adoption/implementation of international tax standards, identify gaps in tax administration machinery, develop tax dispute resolution frameworks, improve taxpayer engagement and compliance and capability building in transfer pricing audits. As an arbitrator, Sarah has experience in chairing arbitration panels and developing bilateral memoranda of understandings and arbitral procedural rules underpinning tax treaty arbitration. As a mediator, Sarah has experience both as a mediator, co-mediator and advocate for taxpayers and fiscal authorities, alike. Sarah is the author of a forthcoming book titled ‘International Tax Dispute Resolution – in practice’ to be published by Wolters Kluwer late 2024