Zoe E. Wyatt Email & Phone Number

Zoe is a partner at Andersen in the UK. She specialises in international tax; developing the blue-print solution to her clients’ cross-border needs, bringing in specialist advice from Andersen Global member firms. https://uk.andersen.com/services/crypto-and-digital-assets/Zoe has always worked within the tech sector and, in particular, in the blockchain and crypto space since 2018. In 2019, she studied Blockchain Strategy with the Saïd Business School, University of Oxford, to better understand the nature of her clients’ business and investments, to structure tax efficiently, mitigating double taxation risk.Zoe and her team are predominantly advising on all the UK and cross-border tax aspects of offshoring for regulatory purposes (e.g. ICOs, crypto exchanges, derivative exchanges, DeFi etc.) including:- use of orphan structures such as Cayman foundations and Singapore guarantee companies to achieve decentralised legal ownership);- use of interim offshore structures (e.g. an offshore subsidiary of a UK company) in order to issue SAFTs to raise initial funds and how to unwind the interim steps;- structuring arrangements between offshore and UK including all relevant anti-avoidance and international tax considerations;- how to leave a pool of tokens in the UK company (for incentivising future employees or for staking) without triggering a disposal or a deemed revenue stream;- managing timing mismatch on tokens coming into the UK company and out to employees / contractors;- VAT on inter-company transactions, electronically supplied services etc.;- how to structure founder / shareholder / employee / contractor tokens tax efficiently;- valuation of tokens / right to tokens;- maintaining the efficacy of offshore structures (i.e. managing corporate residence and PE risk);- impact of a DAO and community voting on corporate residence; and- providing strategic and offshore structuring advice to founders in other high tax and highly regulated jurisdictions, giving directions and ideas to their local advisers to help navigate local anti-avoidance issues;- crypto tax investigations.Zoe is known for her ability to explain and distil complex tax issues in a straightforward manner. She is fascinated with the changing tax landscape and the issue of tax laws not keeping up with new and unprecedented ways businesses operate. Zoe immerses herself in crypto developments. In particular, her clients consider her to be proactive in navigating this field and identifying appropriate planning opportunities and tax risk management policies.