37th Annual Oxford Four-Silk Residential Seminar and Workshop


Tuesday October 1st – Thursday October 3rd

Merton College, Oxford

Early Bird Price £1,350 + VAT

The aim of this year’s residential seminar is once again to examine, in the congenial atmosphere of an historic Oxford College, practical solutions to the ever changing fiscal complications to modern life.

In addition to regular talks, the Seminar will include interactive Discussion Sessions, monitored by one or two of the speakers, in which current tax planning issues will be considered, usually with case studies.


Robert Venables Q.C. (Chairman)

James Kessler Q.C.

Philip Simpson Q.C.

Rory Mullan

Harriet Brown

Keith Gordon

Etienne Wong

Ross Birkbeck

Patrick Boch

Rebecca Sheldon

The speakers are all practising barristers.  They practise from Old Square Tax Chambers, 15 Old Square Lincoln’s Inn, London WC2A 3UE, except Keith Gordon who practices from Temple Tax Chambers, 3 Temple Gardens, London EC4Y 9AU.


TUESDAY October 1st

12.00 Arrival and Registration

13.00 Lunch Merton College

14.00 Chairman’s Introduction

14.10 “Disguised Remuneration” April 5th 2019 Charges – Robert Venables Q.C.

Update on Judicial Review Proceedings – Other Defences – When is the Employer liable for the 2019 Employee Loan Charge? – Employer’s Right of Reimbursement Against Employee? – Consequences of non-reimbursement

14.30 The Transfer of Assets Abroad Code – Rory Mullan

Legislative and case law developments – Davies v HMRC – Fisher v HMRC in the Upper Tribunal – application to contractor loan arrangements – impact of requirement to correct – impact of Brexit

15.20  Coming to the UK: an Overview – James Kessler Q.C.

Pre-arrival planning – Deadlines – Individual’s assets – Individual a trustee – Settlor-interested trusts – Non-settlor interested trusts – Companies – Pre-UK domicile planning – Departure planning

16.10 Discussion Session with Refreshments

16.30 Entrepreneur’s Relief Post Finance Act 2019 – Philip Simpson Q.C.

Relief for previously personal companies – Requirements as to time periods – Requirements as to beneficial ownership

17.15 The Labour Party’s Tax Plans – Rebecca Sheldon

Tax increases announced – preemptive action

18.00 Close of Formal Proceedings for the Day

19.00 Pre-dinner drinks and dinner in the Great Hall


09.30 Chairman’s Introduction

09.35 Penalties for Enablers of Defeated Tax Avoidance – Patrick Boch

Overview of the legislation – “abusive” arrangements and the GAAR advisory panel opinion – “defeated” – what is an “enabler” – information powers – time limits for assessment – naming and shaming – appeals

10.15 Offshore Developments for Private Clients and Trusts – Harriet Brown

The Crown Dependencies New Double Tax Arrangements – Mistake Applications in Offshore Jurisdictions (Including Determining the Appropriate Jurisdiction and A Case Law Update) –  Post-requirement to Correct: Responding to Queries Arising Out of RTC Disclosure and Situations Where There Was A Failure to Disclose – Protected Trusts: Maintaining Protected Trust Status – What Can You Do if a Trust has been Tainted

11.05 Discussion Session with Refreshments

11.20 Avoidance Involving Profit Fragmentation Arrangements – Robert Venables Q.C.

Finance Act 2019 Schedule 4 new TAAR – Interaction with Transfer of Assets Abroad Provisions

12.00  Follower Notices and Advanced Payment Notices – Recent Developments in the Rule of Law – Ross Birkbeck

The FN & APN regimes – Impact on the Rule of Law – Recent developments – Haworth and Unison – Human Rights based challenges – substantive and procedural difficulties Practical points

12.40  Introduction to Discussion Sessions

13.00 Lunch

15.30 The VAT Meaning of “Business” – Etienne  Wong

Why it matters – whether there is a “business” affects whether VAT is payable (an overview) – The historic approach – how the UK defined “business” (the  Lord Fisher test) – The Continental approach – how the CJEU defines “business” –  UK vs Europe – how the Court of Appeal dealt with the competing definitions of “business” (Longridge on the Thames) – The inconclusive conclusion – how the Court of Appeal qualified its own decision (Wakefield College) – Where we are now?

16.15 Discussion Session with Refreshments

16.30 Discussion Session 1

17.15 Discussion Session 2

18.00 Close of Formal Proceedings for the Day

19.15 Pre dinner drinks

19.45 Gala Dinner Merton College (Black-Tie Optional) in the Great Hall – Guest Speaker Sir Stephen Oliver


09.30 – Chairman’s Introduction

09.35 Discussion Session 3

10.20 Dealing with Modern-Day Domicile Enquiries – Keith Gordon

  • The difficulties with long-term residents •HMRC’s tactics •Schedule 36 vs closure notice applications •Final or partial closure notices – Embiricos • HMRC’s flawed reliance on Archer
  • The way forward

11.05  Discussion Session with Refreshments

11.25 Reports of Discussion Sessions Followed by Questions to Speakers

12.45 Lunch

14.00 Close of Seminar


Each Discussion Session will be held three times over, at the times indicated above, to limit the number of those participating in each session.

Discussion Session A: Domicile and Deemed Domicile

Discussion Session B: Capital Gains Tax Liabilities of Non-UK Resident Trustees, their Settlors and Beneficiaries.

Discussion Session C: Taxation of Non-UK Residents re United Kingdom Land



£1, 550 per delegate plus VAT (£310) = £1,860.


For bookings confirmed by August 1st 2019

£1,350 per delegate + VAT (£270) = £1,620.

(to include course notes, accommodation, meals and wines.)


For application and conditions please contact:

Key Haven Publications Ltd, PO Box 669, Oxford OX3 3AU Tel: 01865 352121; Fax: 01865 351081

E-mail: aw.khpplc@khpplc.co.uk

Or visit our website at


Conferences Terms and Conditions

Cancellations: Those confirmed in writing 30 days prior to the Seminar qualify for a refund subject to a £150 charge. Cancellations within 30 days prior to the seminar do not qualify for a refund, although substitutions will normally be allowed at Key Haven’s discretion, subject to a £50 administration fee.

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.

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