– Real Estate Fund Structuring Post BEPS
– SDLT: Chargeable Consideration in Special Cases
– Avoidance & Disputes Update – Pubs, Hotels & Goodwill
– Unwinding Old SDLT JPUT Planning – Essential VAT Update
– The New Capital Allowances Super Deduction
– Tax Insurance in Real Estate Transactions


Michael Thomas – Pump Court Tax Chambers


Nicola Burbridge – Cale Street
Richard Dalton – BDO
Richard Ross – EY
Edward Milliner – Slaughter and May
Michael Gaughan – EY
Kerry Westwell – RSG
William Watson – Slaughter and May
Will Gay – RSG
Sara Maccallum – Boodle Hatfield
Sean Alexander – BDO



9.00 – 9.05  Chairman’s Introduction

Michael Thomas, Pump Court Tax Chambers

9.05 – 09.55  Real Estate Fund Structuring Post BEPS

– Operational and substance considerations
– Treaty considerations
– Cash repatriation and debt reductions
– Potential impact of UK reform on real estate holding structures, including potential impact of:
      – Asset Holding Company regime;
      – UK funds reform
Nicola Burbridge, Cale Street with Richard Ross & Michael Gaughan, EY

09.55 – 10.35  Property Case Book: Hotels, Pubs & Goodwill

– Hotels: rents, trading income and treatment of sale
– Some points arising on sale of a pub portfolio
– Goodwill and “trade related properties”
William Watson, Slaughter and May

10.35 – 10.50 Break

10.50 – 11.40  Avoidance & Disputes Update

– HMRC’s Section 75A Guidance (and its impact)
– SDLT Residential Property Cases and what they show
– More recent cases and why they matter
– Pipeline and where HMRC might attack next
– Resolving disputes before the Tribunal and outside the public eye
Michael Thomas, Pump Court Tax Chambers

11.40 – 12.20  Unwinding Old SDLT Planning in a Modern World: A Case Study

– Identifying the overseas entity – a unit trust or not a unit trust, that is the question
– Key taxes to consider: SDLT, CGT & Corporation Tax, Income Tax
– Impact of a debt in the structure
– Anti-avoidance: How the mechanics of section 75A influence the order of steps & DOTAS
– Using a UK company going forward: Distribution exemption & Group relief possibility
– And if it is not a unit trust…What is it, and what does that mean?
Sara Maccallum, Boodle Hatfield

12.20 – 13.00  Lunch

13.00 – 13.45  Essential VAT Update

– The reverse charge for Building and Construction Services – Practical Aspects
– Balhousie – Differences in interpretation
– Early Termination Payments – impact of RCB 12/2020 in the Real Estate and Construction Sector
– Fund Management Exemption – Where are we now?
Richard Dalton, BDO

13.45 – 14.15 SDLT: Chargeable Consideration in Special Cases

– Deferred, contingent and uncertain consideration – looking in particular at Project Blue (No 2)
– Exchanges of land
– The impact of VAT
Edward Milliner, Slaughter and May

14.15 – 14.30  Tea

14.30 – 15.15  Tax Insurance in Real Estate Transactions – Current Trends

– Expansion of appetite?
– Common tax issues on real estate transactions – what is insurable?
– Hot topics – cover for transfer pricing and loss of tax assets
Kerry Westwell & Will Gay, RSG Transactional Risks Europe

15.15 – 16.00 Capital Allowances & the new Super Deduction

– Overall update on the current capital allowances regime
– Overview of the new temporary first year allowances – the super deduction and SR allowance
– Limitations and opportunities for real estate clients
– Freeports and enhanced capital allowances
– Structures and Buildings Allowances and practical issues
– Summary of the current capital allowances issues and opportunities
Sean Alexander, BDO


16. 00 Conference Closes