Practical Tax Planning – Oxford 2016


34th Annual Oxford Five-Silk Residential Seminar and Workshop


Wednesday September 28th to Friday 30th September

Merton College, Oxford

Early Bird Price £1,125 + 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 talks, a key feature of the Seminar is the Workshop in which case studies and problem papers raising current tax planning issues are considered.


Robert Venables Q.C. (Chairman)
James Kessler Q.C.
Amanda Hardy Q.C.
Christopher Coltart Q.C.
Philip Simpson Q.C.
Patrick Cannon
Etienne Wong
Rory Mullan
Harriet Brown
Setu Kamal
Oliver Marre with Mary Ashley [Joint]

All the above are practising barristers.  They all practise from Old Square Tax Chambers, 15 Old Square Lincoln’s Inn, London WC2A 3UE, except Christopher Coltart Q.C., who practises from 2 Hare Court, Temple.


WEDNESDAY September 28th

12.00 Arrival and Registration

13.00 Lunch Merton College

14.00 Chairman’s Introduction

14.10 Profit Extraction from Close Companies – Robert Venables Q.C.

Disguised Remuneration: Finance Act 2016 changes – threatened Finance Act 2017 Changes – Threatened 2019 Retrospective Charges.  Murray Group Holdings in the Court of Session.   Tightening up by Finance Act 2016 of Transactions in Securities Anti-Avoidance Provisions – New Liquidation Charge to Income Tax.

14.45  Converting Income into Capital Gains – Oliver Marre and Mary Ashley

Fall in capital gains tax rates – Avoiding anti-avoidance rules – Finance Act 2016 changes

15.20 Serial Tax Avoiders and GAAR and POTAS Finance Act 2016 Changes – Philip Simpson Q.C.

GAAR Changes – GAAR Penalties – Serial Tax Avoiders – Changes to POTAS Regime

15.55 Residences as Second Homes or Investments – Patrick Cannon

16.30 Discussion Session with Tea

16.45 – 18.00 Introduction to Workshop Papers

19.00 Pre-dinner drinks and dinner in the Great Hall


09.30 Chairman’s Introduction

09.35 Tax planning after the Panama Papers – Harriet Brown

Do the Panama papers change anything? – Confidentiality and tax planning – The register of beneficial ownership – Exchange of information Future changes

10.10 Charities & VAT – Etienne Wong

The basic position – “business” vs “non-business” – defining what is and is not in scope for value added tax – the VAT treatment of common types of charitable income – admission fees, donations, grants etc – zero (and other non-standard) rated supplies by and to charities – property used for “relevant charitable purposes” (RCP) – what does RCP mean?

10.45 Discussion Session with Coffee

11.00 Public Law ad Tax – Rory Mullan

Challenging HMRC on public law grounds – Choosing the appropriate tribunal – Limitations on public law arguments – Holding HMRC to account – Absence of appeal rights – Procedural fairness – Asserting Convention rights – Information Powers – Legitimate expectations – Settlement agreements

11.40 Savings Surcharges and Exemptions Post Finance Act 2016 -Setu Kamal

Non-Taxable Savings – Non-Taxable Dividends – Effect of non-taxable income on rates of tax on other income, personal reliefs and gift aid relief.  New charges on dividend income.  Taxation of Trust Income.  Tax-efficient planning through trusts and partnerships.

12.15 Changes to Taxation of Foreign Domiciliaries – James Kessler Q.C.

15 year deemed domicile – Formerly domiciled residents – IHT transparency for company holding private residence – Planning implications

13.00 Lunch

15.00 Discussion of Problem Papers in Workshop Groups

15.45 Discussion Session with Tea

16.00 – 18.00 Continuation of Discussion of Problem Papers in Workshop Groups

19.15 Pre dinner drinks

19.45 Gala Dinner Merton College (Black-Tie Optional) in the Great Hall


09.30 – Chairman’s Introduction

09.35  Tax and the Criminal Law:  A Shift in the Landscape – Christopher Coltart Q.C.

The current regime re tax evasion:  present offences (all of which require proof of dishonesty); HMRC investigations policy and COP9 · The new individual strict liability offence of offshore tax evasion ·The new corporate offence of facilitating tax evasion (whether offshore or domestic)

10.10 Judicial Activism Post the Supreme Court Decision in UBS – Amanda Hardy Q.C. 

The role of the modern Supreme Court in 2016 – The decision in UBS AG (Respondent) v Commissioners for Her Majesty’s Revenue and Customs (Appellant) [2016] UK SC 13 – An analysis of “purposive construction” – Bowring v HMRC [2015] UKUT 550 (TCC)

10.45 Discussion Session with Coffee

11.00  Discussion of Problem Papers in Plenary Session followed by Questions to Speakers

12.45 Lunch

Post Lunch Close of Seminar


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


For bookings confirmed by August 1st 2016

 £1,125 per delegate + VAT (£225) = £1,350)

 (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: or visit our website at