Sean Randall and Michael Thomas KC


Thursday 9th November 2023

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James Bromley

James is an experienced tax lawyer at Farrer & Co, having previously worked at Reed Smith. He is well known for his property tax expertise, which spans sales and acquisitions, development projects, landlord and tenant matters and property finance work. He acts for a diverse mix of clients ranging from institutional investors and international developers, to non-profits and individuals. James has a particular interest in SDLT, VAT and tax ownership structures and he is closely involved in shaping developments in UK property taxation. James is an active member of the International Business Structuring Association, the International Association of Young Lawyers, the VAT Practitioners’ Group and the Stamp Taxes Practitioners Group.

Claire Weeks

Claire is a partner in the Private Wealth team at Maurice Turnor Gardner LLP. She is recognised as an expert in providing advice on bespoke multi-jurisdictional wealth planning strategies and investment structures. She has particular experience of advising in relation to the UK taxation of high value residential property, as well as advising ‘non-doms’ on the implications of the various reforms of recent years.

Sean Randall

Sean has 20 years’ “Big Four” stamp duty experience, including running a Big Four UK stamp duty team for five years. He is the chair of the professional body for stamp duty advisers, the Stamp Taxes Practitioners Group, the editor and author of Sergeant and Sims on Stamp Taxes, the author of the Law Society’s SDLT Handbook: A Guide for Residential Conveyancers, the author of the SDLT chapter of Tolley’s Tax Planning 2022-23, a Fellow of the Chartered Institute of Taxation, the winner of Taxation’s Tax Writer of the Year 2017 and listed in Spear’s 500.

Michael Thomas KC

Michael is a barrister at Pump Court Tax Chambers. He advises and litigates in relation to all areas of the UK tax code.

Michael has significant experience of real estate taxation and has advised on countless transactions of all kinds including many large development projects. Recent cases include Hannover Leasing v HMRC concerning Section 75A FA 2003.

He sits on the Tax Committee of the Country Landowners Association. Chambers Bar Guide has said that he is “ahead of the game when it comes to property taxation” and “thought by many to be ‘the go-to man for SDLT advice not he most complicated transactions'”.

Laura Ruxandu

Laura is a barrister at Pump Court Tax Chambers she accepts instructions in all areas of Chambers’ practice including personal tax, corporate tax, VAT, stamp taxes, customs duties and international tax.

Roger Holman

Roger has spent over 24 years specialising in private client taxes, working in accountancy practices, trust companies and law firms. He primarily provides advice to “international” clients, including UK resident non-doms or those moving to and buying assets in the UK. He also supports clients to make sure that their assets and businesses are set up in the best way within the international marketplace. Spear’s Recommended 2022.


09.20-09.30OpeningSean Randall
09.30-10.15Property as an investment: tax for landlords and investorsJames Bromley·       Finding the right ownership structure

·       Maximising reliefs on property income

·       Incorporating investment portfolios

·       Realising investment gains

10.15-11.00The importance of SDLT classificationSean Randall·       Home work

·       Grounds

·       Derelict dwellings

·       Annexes

·       Student accommodation

·       Hotels v serviced apartments

·       Care homes v assisted living

11.15-12.00Inheritance tax on the family home


Claire Weeks·       The basics:  rates, bands, reliefs and exemptions

·       Lifetime gifts and the 7-year rule

·       Reservation of benefit

·       The special regime for trusts

·       Issues with debt

·       Co-ownership arrangements

·       Home loan schemes and their variants

·       Non-domiciliaries and “enveloped properties”

12.00-12.45Capital gains tax and the family homeMichael Thomas KC & Laura Ruxandu·       Availability of principal private residence relief

·       Key tests for relief

·       HMRC challenges and recent developments

·       Practical planning points

13.45-14.30International buyers of UK propertyRoger Holman·       Resident/Non-res buyer

·       Domicile and the remittance basis (a very quick canter through)

·       Structuring a purchase – companies, trusts, personal

·       Commercial

·       Residential investment

·       Residential holiday/home

·       Issues with debt

·       Sales – CGT

·       De-enveloping – still???

·       Development and international clients

14.30-15.15Issue spotting for SDLTSean Randall·       Partnerships

·       Sub-sales

·       Collective enfranchisement

·       Leases

·       Linked transactions

·       Substantial performance

·       Partitions and exchanges

·       Trusts

·       Debt

15.30-16.00VAT & Residential PropertyMichael Thomas KC·       Zero-rating for residential dwellings: availability and limitations

·       Student accommodation

·       VAT and service charges – scope of exemption

·       Ability to save irrecoverable VAT on service charges?

·       Residential conversions and VAT

16.00-16.45Litigation and risk managementMichael Thomas KC·       Where are HMRC attacking?

·       Dealing with HMRC enquiries and disputes

·       Practical steps to minimise risk when undertaking transactions

·       Taking cases to the tribunal (and beyond)

·       Professional negligence and related matters

17.00-17.05ClosingMichael Thomas KC

I’d like to attend

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