Conference Highlights

NRCGT – Update
The Move to Corporation Tax
Sale & Leasebacks, Agreements for Lease & Other Recent Transactions Analysed
Where Are HMRC Attacking for Real Estate Tax?
Full VAT Update, Tricky SDLT Issues & More…


Michael Thomas – Pump Court Tax Chambers


Nicola Westbrooke – EY
Edward Milliner – Slaughter and May
Peter Beckett – KPMG
Richard Dalton – BDO
William Watson – Slaughter and May
Michael Thomas – Pump Court Tax Chambers
Richard Woolich – DLA Piper



9.00 – 9.05  Chairman’s Introduction

Michael Thomas, Pump Court Tax Chambers

9.05 – 09.55  Non UK Resident Capital Gains Regime

– Update to the current rules one year on
– Reporting requirements for investors and funds
– Impact of making the CIV elections
– What we are seeing in the M&A market on NRCGT
Nicola Westbrooke, EY

09.55 – 10.20  Sale & Leaseback Financing

– Application of the structured finance rules and accounting
– The chargeable tax exemption – conditions and traps
Edward Milliner, Slaughter and May

10.20 – 10.30 Break

10.30 – 11.15  Non Resident Landlords Moving to UK Corporation Tax

– Understanding the key differences in respect of financing costs and derivative contracts
– The application of loss relief rules under corporation tax
– The revised tax compliance and tax payment regime
– Consideration of the advantages and disadvantages of migration into the UK
Peter Beckett, KPMG

11.15 – 12.00  Agreements for Lease: Landlord’s Inducements

– Rent-free periods and the impact on SDLT
– Cash payments: reverse premia and capital allowances
– Contributions to fit-out: Cat A and Cat B
– CIS and VAT
William Watson, Slaughter and May

12.00 – 12.45  Lunch

12.45 – 13.40  Practical VAT Updated – Common Pitfalls & How to Avoid Them

– VAT recovery on Deal Fees – Melford Capital General Partner Ltd [2020] TC 07514; could this apply to Real Estate Funds?
– When (and how) to Apportion for VAT on supplies of construction services
– TOGCs – the Option to Tax, Disapplication and what not to do?
– The Domestic Reverse Charge for Building and Construction Services (Again!) – What is in, what is out, and what do you need to do now from a cash flow perspective
Richard Dalton, BDO

13.40 – 14.15 Avoidance & Real Estate Tax Disputes Update

– Anti-avoidance rules: HMRC’s approach and actions areas
– Where else are HMRC attacking?
– Protecting self-assessments from challenge
– Disputes fallout – professional negligence and regulatory
– Recent cases, litigation pipeline and Offshore Property Developers Taskforce
Michael Thomas, Pump Court Tax Chambers

14.15 – 14.30  Tea

14.30 – 15.10  Avoidance & Real Estate Tax Disputes Update (continued)

Michael Thomas, Pump Court Tax Chambers

15.10 – 16.00 What This Year Has Brought… Case Studies for My Desk

– Structuring VAT efficient student accommodation
– Issues on a liquidation – Plant allowances, SDLT, CGT
– The new CGT elections regime for non-resident investors
– Relocating to UK?
– Tough economic times: supplies by Landlords and Tenants
Richard Woolich, DLA Piper

16.00 – 16.15 Panel Session

– Questions on the day (which can be submitted electronically)
– Chairman’s closing remarks

16. 15 Conference Closes