CONFERENCE HIGHLIGHTS
– Property Holding Structures
– Asset Holding Companies
– RPDT & Other Matters
– Sovereign Immunity & Finance
– SDLT Hot Topics
– VAT Update
– Real Estate Litigation
– Latest Trends in Tax Insurance
CHAIRMAN & SPEAKER
Michael Thomas, Barrister – Pump Court Tax Chambers
SPEAKERS
Edward Milliner – Slaughter and May
Richard Ross – EY
Michael Gaughan – EY
Jemma Dick & David Saleh – Clifford Chance
Richard Woolich – DLA Piper
Lisa Oakes – BDO
Adam Singer – Certa Insurance
TIMETABLE
9.00 – 9.05 Chairman’s Introduction
Michael Thomas, Pump Court Tax Chambers
9.05 – 09.50 Property Holding Structures & Joint Ventures
– Choosing the vehicle
– Changing the vehicle
– Bringing in a JV partner
Edward Milliner, Slaughter and May
09.50 – 10.40 Asset Holding Companies, RPDT & Other Matters
– Review of Asset Holding Company Regime and use in real estate investment funds
– Impact of Residential Property Developer Tax “RPDT” on UK real estate structures
– Consideration of other international tax developments for real estate sector
Richard Ross & Michael Gaughan, EY
10.40 – 10.55 Morning Break
10.55 – 11.45 Topical Problems: Sovereign Immunity & Finance
– UK Sovereign immunity consultation – What is happening and why is it so significant for real estate?
– Recent case law developments impacting real estate financing transactions. Are they game changers?
1. transfer pricing (Blackrock)
2. unallowable purposes (Oxford Instruments, JTI, Blackrock)
3. UK source on interest payments (Hargreaves and Ardmore)
Jemma Dick and David Saleh, Clifford Chance LLP
11.45 – 12.20 SDLT Hot Topics
– Section 75A update
– Recent commercial property cases including Tower One St George Wharf
– Residential property cases update
– When is Para 34A Sch a car to NDR reclaims following Smith Homes 9 Ltd
Michael Thomas, Pump Court Tax Chambers
12.20 – 13.10 Lunch
13.10 – 14.00 VAT: Update & Topical Issues
– Dangers of disapplication of options to tax
– Haymarket and how far you can push the TOGC rules
– Titanium and fixed establishments
– Scope of zero rating for installation of energy saving equipment
– Scope of reliefs on converting and constructing residential property
– Management contracts and “relating to land”
Richard Woolich, DLA Piper UK LLP
14.00 – 14.40 Real Estate Tax Litigation
– Offshore Property Developers Taskforce update and retrospective
– Where are HMRC attacking
– Strategies for keeping disputes out of the Tax Tribunal
– More recent cases
Michael Thomas, Pump Court Tax Chambers
14.40 – 15.00 Tea Break
15.00 – 15.50 Ground Rent Transactions & NRCGT & The Trading Exemption / SSE
– Key reliefs
– Interaction with corporate interest restriction rules
– Valuation matters
– Ambiguity where trading subsidiaries recently acquired
– Filing requirements
– Discounting for latent gains in property transactions – accounting policies and practical issues
Lisa Oakes, BDO
15.50 – 16.10 Latest Trends in Tax Insurance
– When can tax insurance be used
– What is insurable
Adam Singer, Certa Insurance Partners
