Old Square Tax Chambers is hosting an afternoon seminar on 3 May 2018 where James Kessler QC, Rory Mullan and Ross Birkbeck will be speaking on Current issues in offshore tax matters.
The seminar is to be held from 4.00 pm to 6.15 pm in The Old Hall, Lincoln’s Inn and the timetable will be as follows:
4.00 – 4.15 Tea & Coffee
4.15 – 4.50 Rory Mullan will speak on The Requirement to Correct Rules – scope of the obligation and when it arises – consequences of non-compliance – dealing with uncertainty – relying on professional advice to avoid penalties.
4.50 – 5.25 Ross Birkbeck will speak on Domicile of Choice Enquiries – Dealing with enquiries on domicile of choice – enquiry procedure and evidence – responding to requests – Schedule 36 defences – Applications for final and partial closure notices
5.25 – 6.00 James Kessler QC will speak on F(no.2)A: Professional Bodies Q&As and will address The F(nol.2)A 2017 made important changes to the taxation of foreign domiciliaries. This lecture will consider the questions and draft answers published by the professional bodies on 27 March: – Q&As Trust protections – Q&As Mixed fund cleansing – Q&As Rebasing and the adjustments to the CGT foreign capital losses election
6.00 – 6.15 Question to the speakers followed by drinks
Drinks will be hosted immediately after the seminar at which you will have an opportunity to meet members of Old Square Tax Chambers.
The seminar is free of charge.
Please let us know if you wish to attend by emailing email@example.com and do feel free to inform any colleagues who might be interested in joining us.
Etienne Wong will be speaking at the Financial Compliance for Law Firms – 2018 Conference on 19th April 2018, which is hosted by MBL Seminars.
Further details can be seen here.
Etienne Wong will be presenting two webinars that will be available for stream and download on 2nd May. Further details can be seen below:
Etienne Wong was recently featured in the Tax Journal’s “Ask an expert” where he covered the topic of “Initial coin offerings and VAT”. A copy of the article can be seen here*.
*This article was first published in the 16 March 2018 issue of the Tax Journal, and is reproduced with the kind permission of the publishers. All rights reserved.
Etienne Wong will be speaking for MBL Seminars at the Financial Compliance for Law Firms – 2018 Conference on 19th April 2018.
This session will discuss two recent decisions: one shining a spotlight on how law firms should treat disbursements for VAT purposes; the other on how law firms should determine who to invoice for VAT purposes on transactions where third parties foot the bill.
This session will cover:
- The first tier tribunal decision on what is a disbursement
- The supreme court judgment on how to determine who is the recipient of a supply for VAT purposes
- How disbursements should be treated in a bill of costs
- How to determine who to bill
- Reconciliation with old – and updated – Law Society guidance
Taxation of UK Land and Buildings
An Extended Afternoon Seminar at The Law Society’s Hall, London WC2A
Wednesday May 9th 2018
Fees £575 + VAT (of £115) = £690
With early bird price for bookings confirmed before April 9th of £520 + VAT (of £104) = £624.
Since the Brexit Referendum, the screws of UK tax law continue to be tightened to increase taxes on UK land. Most affected are companies, trusts and individuals resident (or domiciled) outside the UK. Is this some cunning plan to encourage the foreign investment which will be so badly needed once the UK has left the EU?
First, the anti-avoidance rules which tax capital gains as income were replaced wholesale by more Draconian provisions and non-UK residents who make gains from UK land have been subjected to new charges on income even when they do not trade in the UK through a permanent establishment, in each case without any consultation.
Next, new rules were enacted to prevent indirectly held UK resident property interests falling outside the charge to inheritance tax as excluded property.
Now, there are proposals for the taxation of non-UK residents in respect of capital gains from directly or indirectly held UK real property of any description.
Next, will do doubt be the extension of the inheritance tax rules to all indirectly held UK real property interests.
The rates of SDLT have been greatly increased and the rules become more complex than ever.
VAT on UK land, never a simple topic, has become horrendously complex, even before Brexit.
A panel of barristers will discuss tax planning in the light of these changes and likely future changes.
Robert Venables Q.C. (Chairman)
All the speakers are from Old Square Tax Chambers, Lincoln’s Inn, WC2A 3UE, 020 7242 2744, firstname.lastname@example.org.
12.00 Registration and Buffet Meal
13.00 Chairman’s Introduction
13.05 Trade of Dealing in United Kingdom Land & New Anti-Avoidance Provisions – Robert Venables Q.C.
New Finance Act 2016 Regimes for corporation tax and income tax – Widened Scope of Charge – Comparison with Replaced Anti-Avoidance Provisions – Irrelevance of permanent establishment – Unexpected Effects
13.45 Taxation of Non-UK Residents on Chargeable Gains from United Kingdom Land – Sarah Squires
The present regime: ATED gains and NRCGT gains on residential property interests – The Consultation Document Taxing gains made by non-residents on UK immovable property: extension of direct charge to all United Kingdom property interests – introduction of charge on indirectly held United Kingdom property interests – transitional provisions
14.30 Current SDLT Issues – Patrick Cannon
When can you claim the lower rates for mixed use property? – SDLT Follower Notices after Geering v HMRC  – Is there a gap in the 3% additional rate for joint owners who purchase another dwelling? – Supreme Court decision in Project Blue – FA 2018 SDLT changes
15.10 Inheritance Tax on Indirectly Held United Kingdom Residential Property Interests
Finance (No 2) Act 2017 Changes – Interests in Companies and / or Partnerships – Creditor’s Rights under Loans – run-off charge the TAAR – Extension to all United Kingdom property interests?
15.40 Current VAT Issues – Etienne Wong
Non-resident landlords, managing agents and “fixed establishments” – HMRC’s current position; Novating sale contracts; Recovering VAT on property developments – Iberdrola; Using land to pay tax (and distributions in specie); Non-business charitable use, incorporating existing buildings in residential developments – is Brexit the answer?”
16.20 Discussion Session with Tea
16.35 Double Taxation Conventions and EU Law Defences – Robert Venables Q.C.
Wording of Double Taxation Conventions – Limited Treaty Override – EU Override
17.00 Questions to Panel and Discussion Session
17.30 Close of Seminar
Cancellations in writing 14 days prior to the seminar qualify for a refund subject to a £50 charge. Cancellations within 14 days prior to the seminar do not qualify for a refund.
Disclaimer: Key Haven Publications Ltd reserves the right to change the speakers or the programme for any reasons beyond its control or on account of changes in the law. Nothing in the talks or discussions or the prepared notes constitute legal advice. They are simply an expression of the speakers’ views, put forward for consideration and discussion. No action should be taken nor omitted in reliance on them but independent professional advice should be taken in every case. Neither the speakers nor Key Haven Publications Ltd accept any legal responsibility for them.
Warning: Neither Key Haven Publications Ltd nor the speakers gives any licence to any person to record and/or reproduce in any format (including sound and/or visual recording) (a) any Notes prepared in conjunction with this seminar; (b) the delivery by any speaker of any talk or any response to any question or discussion, in whole or in part, on any of the above. Any such unlicensed recording or reproduction or the making of any such epitome or transcript is a civil wrong and could well involve the commission of a criminal offence.
Patrick Cannon has recently written an article for the Tax Journal entitled “Recent judicial review challenges to HMRC search warrants”. A copy of the article can be seen here.
Harriet Brown will be presenting “A Practical Guide to the New Non-Dom Rules” for MBL Seminars on March 1st in London.
Further details about the seminar can be found here.
Chambers directory notes: Old Square Tax Chambers is well known for handling taxpayer-side litigation. Members of the set are often instructed in high-profile and sophisticated tax cases, frequently involving ultra high net worth individuals. Counsel at Old Square Tax also have strong advisory practices.
The clerks at Old Square Tax Chambers are repeatedly praised by interviewees. “They are excellent and very efficient,” says one source. “They always call back and do everything they need to do and on a timely basis. I recommend them all.”