Sarah Churton

Sarah leads KPMG’s Life Sciences Tax Team in the UK. She focuses her time almost exclusively in the life sciences sector where she has a wealth of experience advising UK and non-UK headquartered groups of varying sizes and stages of commercialisation on cross-border tax issues.

Sarah has considerable experience in advising companies on cross-border tax issues such as IP centralisation and restructuring, the UK’s response to Base Erosion and Profit Shifting (BEPS), group reorganisations, intra-group financing and Brexit. She has advised a spectrum of life sciences companies from the largest global Pharma companies to smaller biotech companies that are pre-IPO.

Previous to her role at KPMG Sarah spent over two years based in New York, providing UK tax advice and insight to US-headquartered groups.

She has been a long-standing member of HMRC’s Patent Box working group and most recently is leading KPMG’s response to the UK consultation on the taxation of intangibles.

Representative experience in the Pharma and Biotech sector

• Advising on the UK tax consequences of a separation of two businesses into separate legal entities

• Advising on the integration of local operating companies following acquisitions

• Advising on the application of the UK’s Diverted Profits Tax and agreement of the position with HMRC

• Advising on the application of the UK’s Anti-Hybrid rules and on consequent restructuring

• Advising on cross-border restructuring of IP, including centralisation of IP in the UK and divestment of IP from the UK

• Advising on the application of the UK patent box and assistance with HMRC engagement.