Abigail McGregor

Legal Director, Pinsent Masons

Abigail is a Legal Director in the Tax Disputes team. She specialises in tax matters of actual and potential dispute with HMRC, and has a background in transactional tax. She works with clients and the wider tax teams to identify areas of tax risk in new taxes as they are developed and introduced, which has included the introduction of Plastic Packaging Tax, the Electricity Generator and Oil and Gas levies, as well as the impact of the notification of uncertain tax treatment rules. Abigail’s role has a broad remit, providing technical assistance to clients and members of the team on all areas of contentious tax including interpretation of tax law, tribunal procedure and HMRC collection and enforcement powers. She regularly writes thought leadership pieces in the tax press, including Tax Journal, Taxation and LexisPlus. Abigail was appointed as a fee paid judge in the FTT in 2015 and continues to sit on a part-time basis on a range of tax cases.

Contributed to

2

Compensation payments made by banks—non-deductibility and notional trade receipt

Practice Notes

This Practice Note explains the rule that prevents banking companies from claiming tax deductions for compensation expenses and adds a sum equal to 10% of the non-deductible compensation expense to the relevant banking company’s taxable profits. This Practice Note has been produced in partnership with Jake Landman and Abigail McGregor of Pinsent Masons.

Tax

Scottish Aggregates Tax

Practice Notes

What is the Scottish Aggregates Tax?The Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024 (ATDTA(S)A 2024) brings into force the Scottish Aggregates Tax (SAT) in Scotland from 1 April 2026 replacing the UK Aggregates Levy (UKAL) for the taxation of aggregate in Scotland. Until that date, the UKAL continued to apply in Scotland. Similar to the UKAL, the SAT is an environmental tax. It is administered by Revenue Scotland on the commercial exploitation of aggregates in Scotland. The Scotland Act 2016 provided the Scottish Parliament with the power to introduce a devolved replacement for the UKAL.The SAT has been designed as a replacement for the UKAL in Scotland with the explicit aim of minimizing complexity and preventing businesses which had not previously been within scope of Aggregates Levy from becoming liable to the tax.The SAT also ensures that double taxation is avoided on aggregate which has been supplied cross-border by middlemen in a supply chain, such as builders merchants, by ensuring that the aggregate which

Environment