Real Estate Tax - 2025 - PRT Conferences

Sophie Lloyd, Ashurst

Sophie is a Counsel at Ashurst with a broad practice advising clients including pan-European real estate funds, REITs, sovereign wealth investors and real estate and global asset management firms on direct tax, VAT and stamp tax implications of a diverse range of transactions. She has extensive experience structuring joint venture arrangements in the real estate and infrastructure sectors. Sophie also has experience advising clients in relation to fund formations, group reorganisations, establishments of new asset managers, secondary transactions and HMRC enquiries, assessments and information requests.

Michael Thomas KC

Michael is a barrister at Pump Court Tax Chambers. He advises and litigates on all areas of the UK tax code. For over two decades he has had a notable specialism in real estate tax. During that time, he has advised on countless development and investment projects of all shapes and sizes. Michael acts for taxpayers in disputes against HMRC, both by acting as advocate before the Tax Tribunal and Higher Courts and in providing strategic and tactical guidance to achieve early resolutions. He sits on the ICAEW VAT and Duties Committee and the Tax Committee of the Country Landowners Association.

Chris Nyland

Chris has specialised in the taxation of real estate and the built environment for two decades, practising as a solicitor and a Chartered Tax Adviser. He has been an embedded expert in real estate groups alongside lawyers, accountants and surveyors, including at Deloitte and at Gowling WLG, where he was a partner. Chris provides consultancy services to some of the largest property operators in the UK in relation to development and investment in the commercial and residential sector. He is an active member of the British Property Federation’s VAT Committee and the CIOT’s property taxes subcommittee as well as a regular contributor to Tax Journal.

Richard Woolich, DLA Piper

Richard is a tax partner at DLA Piper UK LLP. He is the co-author of Sweet & Maxwell’s Stamp Duty Land tax, recently publishing the 5^th Edition. He was this year voted Indirect Tax lawyer of the year by International Tax Review, has been recommended individually in the Legal Directories for many years and is currently in the Hall of Fame for VAT and Indirect Tax. Richard has a broad practice in real estate tax, leading the UK VAT practice at DLA Piper and co-leading the International VAT practice.

Michael Gaughan, EY

Michael is a Director in the Real Estate tax department at EY. He specialises on advising on UK tax aspects of Real Estate transactions, reorganisations and financings. Michael has a particular focus on UK REITs. He advises leading listed and privately owned REITs.

Jemma Dick, Clifford Chance

Jemma Dick and David Saleh are partners in the tax department at Clifford Chance. Jemma specialises in advising on the UK tax aspects of finance, capital markets and transactions. Jemma has particular experience in advising on real estate finance and structure finance deals. Her clients include leading banks, financial investors and corporates.

David leads Clifford Chance’ Real Estate and Indirect Tax practice and his clients include some of the world’s leading multinationals, private equity houses, governments and sovereign funds. David also advises clients on tax policy and tax disputes.

David Saleh, Clifford Chance

Toby Price, Deloitte

Toby has run the Deloitte UK stamp taxes practice for 10 years and has practiced in this area full-time for 25 years. His work covers due diligence, restructuring, development or corporate occupier related issues, as well as transactions involving UK shares, such as mergers and acquisitions, group restructuring and public listings.

TIMING	SUBJECT	SPEAKER	BULLETS
08:40 – 09:00	Welcome		Tea, coffee & pastries
09:00 – 09:05	Chairman’s Introduction	Michael Thomas KC
09:05 – 09:45	Joint Venture Real Estate Platforms –key tax considerations throughout the lifecycle from Heads of Terms to Exit	Sophie LLoyd, Ashurst	Heads of Terms – what to think about at the outset The JVA – what tax drafting requires particular attention? Special cases: REITs During the life of the JV and looking ahead to exit – what tax issues to expect.
09:45 – 10:30	The New Inheritance Tax Business Landscape – What to do now Business Property and Agricultural Reliefs will be restricted?	Michael Thomas KC	What are the new rules? Obstacles to avoiding IHT on land rich businesses (including farms, other trading businesses and property investment businesses) What opportunities are left? Finding the best strategy
10:30 – 10:50	Break		Tea, coffee & biscuits
10:50 – 11:35	Be it let: leasing words of wisdom for the commercial sector	Chris Nyland	Evolution of the landlord-tenant relationship Inducements: balancing stamp taxes, VAT, capital allowances and CIS Regearing: unwitting transactions on variations and surrenders-and-regrants Assignments: tax traps for the unwary on £1 assignments Ending leases: surrenders, terminations, and HMRC’s tinkering
11:35 – 12:20	VAT Strategies	Richard Woolich, DLA Piper	Input VAT recovery: pitfalls and strategies Case studies in practice Holding company strategies Lessons from recent case law including: Hotel La Tour, Visual Investments Limited and Sonder Europe Limited.
12:20 – 13:20	Lunch
13:20 – 14:05	UK REITs – Use in Structures following reforms	Michael Gaughan, EY	Summary of the amendments to the UK REIT regime Comment on the increased flexibility in using REITs in investments. Examining the commercial upsides of REITs
14:05 – 14:50	Latest Tax Issues in Real Estate Finance	Jemma Dick and David Saleh, Clifford Chance LLP	Tax due diligence – high risk/material issues and documentary mitigants for Lenders Cash repatriation for debt service – beneficial ownership/substance/PPT developments following the Danish conduit cases and lender tolerance for risk To REIT or not to REIT? – niche points for financings CIR -groups and PIE Debt fund lenders and back leverage – specific risks for borrowers
14:50 – 15:15	Tea
15:15 – 16:00	Navigating past some of the SDLT traps hiding in the following scenarios	Toby Price, Deloitte	Non-resident surcharge on purchase by UK company Flat rate charge on purchase of residential property by company Separating couples selling matrimonial home securing replacement relief from additional homes surcharge Lease agreements which are substantially performed Withdrawing cash from property partnerships Sequencing subsale arrangements Forward funded development under long lease Group relief clawback outside the three year clock
16:00 – 16:45	Contentious Real Estate Tax Update	Michael Thomas KC	Recent cases Implementing transactions and documenting evidence The statutory review procedure in practice Where are HMRC attacking? Appropriations to trading stock after Stolkin
17:00	Conference Closes

Real Estate Tax – 2025

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