Senior Lecturer

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Research Interests

Sandra Eden's main area of research interest is tax law and policy. She is also an expert in pension law, especially the taxation of pensions. She has published widely in these fields. She has also published articles on questions of legal process and access to justice.


Sandra Eden's homepage at Edinburgh Law School

Research Interests

Sandra Eden's main area of research interest is tax law and policy. She is also an expert in pension law, especially the taxation of pensions. She has published widely in these fields. She has also published articles on questions of legal process and access to justice.


Sandra Eden's homepage at Edinburgh Law School

Courses Taught

Principles of European Tax Law (LLM)

Principles of International Tax Law (LLM)

Revenue Law (Ordinary) (Course Organiser)

PhD Supervisees

Qiang Cai  'International Tax Arbitration (ITA) : obstacles and proposals'

Anna-Archontia (Arianna) Florou  'CFC rules: the (in)effectiveness of the OECD BEPS Action Plan and EU law in fostering global convergence and the quest for an optimal solution'

Books and Reports

Sandra Eden, Colin Tyre, Tax for Litigation Lawyers, (W. Green and Son Ltd, 2000)

Sandra Eden, Inheritance Tax in Scotland, (Butterworths Law (Scotland), 2000)

Sandra Eden, Stephen Woodhouse, Stuart Lippiatt, Taxation of Pension Schemes, (Sweet and Maxwell, 1996)

Sandra Eden, D. Nichols, Scottish Family Law Service, (Edinburgh, Butterworths,, 1995)


Sandra Eden, 'The Obstacles Faced by the European Court of Justice in Removing the "Obstacles" Faced by the Taxpayer: The Difficult Case of Double Taxation', (2010), British Tax Review, Vol [2010], pp 610-28
Abstract: This article reviews the case law of the European Court of Justice both before and after the landmark decision in 2006 of Kerckhaert-Morres on double taxation. It concludes that the position was finely balanced prior to the decision and the Court could have decided either way, although subsequent cases have been consistent with the decision. It considers whether the Court made the right choice and concludes on pragmatic grounds that it did.

Sandra Eden, 'Judicial Control of Tax Negotiation ', (2005), eJournal of Tax Research, Vol 3, pp 5-27
Abstract: This article considers the supervisory jurisdiction of the UK courts through an examination of their control of the UK tax authorities. It concentrates on the conditions under which the tax authorities have been authorized by the UK courts to enter extra statutory arrangements to afford some taxpayers concessional treatment. The article considers the basis of judicial review and then examines the legislative framework within which the Revenue operates. With this background the article considers the principles of judicial review in tax cases. Starting with the general principles, it then examines the argument that the Revenue makes extra statutory concessions on the basis of its powers of care and management and it considers the limitations of that argument. The cases dealing with legitimate expectation are examined too, as are the limits on the legitimate expectation principle. Finally, the article considers the slippery principle of equality within the UK constitution and the equally frustrating (for third parties) problem of establishing locus standi. The article concludes that there are significant tensions between competing interests when the Courts review the Revenue's granting of extra statutory concessions. They seem to have afforded the taxing authorities considerable autonomy in their fulfilment of their management function, but they have limited them to the exercise of discretion only in the course of their care and management of the tax system and in the context of their primary duty to collect tax. The author concludes that the courts have done well in balancing the interests of the tax authorities and taxpayer but that wider interests, such as equality between taxpayers, have not fared as well.

Sandra Eden, 'More Cautionary Tales ', (2004), Edinburgh Law Review, Vol 8, pp 276-78

Sandra Eden, 'Cautionary Tales - the Continued Development of Smith v Bank of Scotland ', (2003), Edinburgh Law Review, Vol 7, pp 107-18
Abstract: An analysis of the cautionary wives cases in Scotland against developments in England.

Sandra Eden, 'UK Taxation of Cross-border Pension Provision ', (2001), European Taxation, Vol 41, pp 73-79
Abstract: Analysis of the UK taxation of pension provision.

Sandra Eden, 'Fairness and the division of pension rights on divorce ', (2001), Greens Family Law Bulletin

Sandra Eden, 'The end of the road for the Birmingham 60,000? ', (2001), Greens Employment Law Bulletin

Sandra Eden, 'The Working Families' Tax Credit and the Disabled Person's Tax Credit ', (2000), Greens Family Law Bulletin, Vol 35, pp 1-3
Abstract: Anaylsis of the new rules on tax credits

Sandra Eden, 'Corporate Tax Harmonisation in the European Community ', (2000), British Tax Review, Vol 6, pp 624-52

Sandra Eden, 'Some Awfully Big Questions on Tax Sovereignty v Level Playing Fields ', (2000), EC Tax Journal, Vol 4, pp 11-44

Sandra Eden, Harry Smith, 'Valuation of Pension Rights Revisited ', (1999), Greens Family Law Bulletin, pp 3-5

Sandra Eden, 'Pension Sharing on Divorce: The New Rules (a Start)', (1999), British Tax Review, pp 361-65

Sandra Eden, 'Employment Termination settlements ', (1999), Greens Employment Law Bulletin

Sandra Eden, 'The Implementation of the Scottish Tax Varying Power ', (1998), Scotland Forum, pp 6-7

Sandra Eden, 'Emoluments therefrom - the litigation continues ', (1998), Greens Employment Law Bulletin, pp 7-8

Sandra Eden, 'Credit Limited for Discretionary Trusts ', (1998), Tolley's Practical Tax, Vol 19, pp 57-60

Sandra Eden, 'Taxing Times Ahead for the Scots ', (1998), Scots Law Times, pp 57-61

Sandra Eden, 'A Clash of Two Cases ', (1997), Taxation, Vol 139, pp 266-70

Sandra Eden, 'Structured Settlements ', (1996), Greens Employment Law Bulletin, Vol 11, pp 3-4

Sandra Eden, 'Pensions and Divorce ', (1996), Greens Employment Law Bulletin, Vol 23, pp 3-5

Sandra Eden, 'A History of the Taxation of Private Pensions ', (1996), British Tax Review, pp 46-70

Sandra Eden, 'Taxation of Payments on the Termination of Employment ', (1996), Greens Employment Law Bulletin, Vol 16


Luca Cerioni, Sandra Eden, 'The United Kingdom ' in Edoardo Traversa (ed.) Corporate Tax Residence and Mobility (International Bureau of Fiscal Documentation 2018)

Sandra Eden, 'Taxing Benefits in Kind Theory and Practice' in Jeorg Manfred Moessner (ed.) Taxation of Workers in Europe (European Association of Tax Law Professors 2010) 39-49

Sandra Eden, 'A Tax on All Blue Eyed Persons Constitutional Limitations on Tax Raising Powers in the UK' in Joseph Edney, Marco Greggi (ed.) Bridging a Sea (Aracne 2010) 175-204

Sandra Eden, 'Chapter 8 ' in Greens Scottish Business Administration Manual (Greens Professional 2000) 8/1-8/16

Sandra Eden, 'The Taxation of Electronic Commerce ' in Lilian Edwards, Charlotte Waelde (ed.) Law and the Internet (Hart Publishing 1997) 151-79

Sandra Eden, 'The Escape of Houdini and the Restraint of the New Approach ' in Scots Law into the 21st Century (W. Green / Sweet & Maxwell 1996) 146-59

Sandra Eden, Alan Barr, 'Checking and Revising Tax and Related Matters ' in John M. Halliday, Iain J. S. Talman (ed.) Conveyancing Law and Practice (Edinburgh, W. Green/SULI . 1996)

Sandra Eden, 'Taxation ' in David Brownlee, David I. Nichols, Alison Cleland, Andrew Cubie, Brian Kearney, George Jamieson, Jane Mair, Ian Maxwell, Alexandra Plumtree, Margaret Ross (ed.) Scottish Family Law Service (Edinburgh, Butterworths, 1995) Division A, §§222-35, 351-52, 584-624. 781-800, 1261-99, 1491-96, Division C, §§2301-65