Rebecca Sheldon will be speaking at EANOVAT Annual Conference on the 6th of September.
For further details, please follow the link here.
Etienne Wong and Rebecca Sheldon were speakers on developments in VAT and indirect tax. They discuss the recent updates on some key developments in VAT and indirect tax. The webinar was organised by Lexis Nexis.
Please follow the link below for further details.
11th of July 2019
Sarah Squires has been recently listed as one of LexisPSL’s contributing authors, following the update of her practice note on the qualifying private placement exemption from withholding tax, as well as updates of her practice notes on the UK tax treatment of alternative finance arrangements (including murabaha, musharaka, sukuk and ijara).
The practice note on the qualifying private placement exemption can be seen below:
[This updated Practice Note was first published on Lexis®PSL Tax on 18 July 2018, and is reproduced with the kind permission of the publishers. All rights reserved” and are reproduced with the kind permission of the publishers. All rights reserved.]
KEY HAVEN PUBLICATIONS LTD
37th Annual Oxford Four-Silk Residential Seminar and Workshop
PRACTICAL TAX PLANNING 2019
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.
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
WEDNESDAY OCTOBER 2nd
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
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
THURSDAY OCTOBER 3rd
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
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.
SPECIAL EARLY BOOKING DISCOUNT
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
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.
Old Square Tax Chambers has entered a team for the London Legal Walk 2019, taking place on the 17th June. James Kessler QC, Patrick Boch and Rebecca Sheldon will be running the 10k River Route to raise money for and support charities that provide or host free legal advice services.
Sarah Squires will be providing an update on recent UK tax developments as they impact commercial property investments at a Commercial Property Development conference by MBL Seminars in London on June 2019
For more information, including how to register for the seminar, please see here.
The seminar was held from 16:00pm to 20:00pm on 22nd of May 2019 in the Radisson Blu Edwardian Manchester Hotel and the timetable was as follows:
Copies of the speakers’ notes are now available to download here.
16:00 – 16:15 Tea & Coffee
16:15 – 16:50 Philip Simpson QC will speak on Information requests from HMRC and abroad
Scope and extent of the powers; limitations on HMRC; routes to challenge
16:50 – 17:25 Rebecca Sheldon will be speak on The Appeals Process
What can be appealed; how to appeal; time limits; making late appeals
17:25 – 18:00 Rory Mullan will be speak on HMRC Enquiries
Dealing with length and cost; time limits; engaging with HMRC and the dangers of not doing so; bringing matters to a close; partial closure notices
18:00 – 18:15 Questions to the speakers
18:15 – 20:00 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 any future seminars by emailing email@example.com and do feel free to inform any colleagues who might be interested in joining us
Rory Mullan and Harriet Brown were speakers on Inaugural Tax for General Practice on 30th of April 2019. They discussed the important tax issues currently affecting legal practice, including matters arising from the Chancellor’s 2019 Spring Statement. The webinar was organised by Lexus Nexus.
7th of May 2019
The First Tier Tribunal has decided in favour of the taxpayer in Embiricos v HMRC TC/2018/03753, in the first decision to examine the scope of the Partial Closure Notice regime introduced by Finance (No2) Act 2017.
In a ruling that could have wide application in the enquiry process, Judge Robin Vos accepted Mr Kessler’s submissions that the Court of Appeal decision in R (Archer) v HMRC  EWCA Civ 1962 did not apply to partial closure notices, and that a partial closure notice in respect of the taxpayer’s domicile could be issued despite HMRC not yet knowing the amount of tax that was due as a result of their decision on the domicile issue.
10 April 2019