Join Us - 8 December 2021

Taxation of Offshore Structures:
What Practitioners Must Know

Location: Live Online
Event Overview

Taxation of Offshore Structures:
What Practitioners Must Know

This Conference by Field Court Tax Chambers focuses on the burning topics on the taxation of offshore structures.

  • We have an international team which will look at transfer pricing; the panel contains the leading practitioners in the area.
  • There will be special talks on the optimum structures for offshore investment funds, property investment holdings and sportsmen.
  • There are a number of specialist talks on topics which are arising in practice – trust registration, tax classification of civil law entities, establishing oneself as a trader in financial instruments, creating a foreign source for interest, tax investigations by HMRC of foreign structures, the new RPDT (residential property developer tax) and the treatment of loans in offshore structures.

This is a must for practitioners advising in this challenging area.

Conference Format:

One day

Ticket Information:

£500+VAT

Running Time:

9.15am - 5.45pm

Location:

Live Online

CPD:

7 Hours

Our Speakers

Expertise in depth

Patrick C Soares

Patrick C Soares

Head of Chambers     …genuinely fantastic; a walking encyclopaedia on tax

Patrick C Soares

Patrick Way QC

Patrick Way QC

Barrister     The consummate lawyer

Patrick Way QC

Philip Baker QC

Philip Baker QC

Barrister     A guru on treaty and cross-border tax

Philip Baker QC

Imran S Afzal

Imran S Afzal

Barrister     Really clever and very assiduous

Imran S Afzal

Peter Vaines

Peter Vaines

Barrister     Incredibly technically able… a legend in the field of residence and domicile

Peter Vaines

Katherine Bullock

Katherine Bullock

Barrister     highly creative, always pragmatic

Katherine Bullock

Dilpreet K Dhanoa

Dilpreet K Dhanoa

Barrister    

Dilpreet K Dhanoa

David Southern QC

David Southern QC

Barrister     the perfect balance between technicality and practicality

David Southern QC

David Bloom QC

David Bloom QC

Barrister (Australia)     the best tax silk in the country Commentator to Chambers Asia-Pacific

David Bloom QC

Porus F Kaka

Porus F Kaka

Barrister     The International face of Indian tax practice

Porus F Kaka

Oktavia Weidmann

Oktavia Weidmann

Barrister (Germany)    

Oktavia Weidmann

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Reasons To Attend

Why You Should
Attend

A fantastic opportunity to hear top tax barristers discussing topical issues from the comfort of your own space

Event Schedule

When, What, Who

9:15 - 9:20 am

Introduction

Chairman's welcome and opening remarks.

9:20 - 9:30 am

Update on Recent Changes

Once again Patrick Soares takes long, serious subjects and reduces them to short, sharp need-to-know gems.

9:30 - 10:15 am

International Transfer Pricing Forum - United Kingdom, Australia and India

A round up of recent cases and other developments from Australia, India and the UK, and further afield debated by three leading experts from three continents.

10:15 - 10:45 am

Permanent Establishment - Current Problems

  • The changes introduced following BEPS and in the 2017 Model
  • Recent case law on PEs
  • Attribution of profits – the nightmare continues
10:45 - 11:00 am
11:00 - 11:30 am

Attracting UK Investment Managers to the UK

  • The definitive guide to investment fund taxation
  • Hedge fund and PE structures
  • Incentivising the fund manager
  • The carried interest conundrum and how to solve it
  • Structures for the new investment wave
11.30 - 12:00 pm

Infrastructure Funds & Offshore Groups Investing in UK Property - Ideal Structures

  • Dangerous loans
  • The holding of the investment
  • The financing of the investment
  • Returning profits
  • The overseas landlord scheme
  • The loan relationship rules
  • The corporate interest restriction
  • The loss carry-forward rules
  • Accounting issues
12:00 - 12:30 pm

Offshore Close Companies; UK Property; Relevant Loans and Situs - New Rules on Location

  • FA 2017 IHT rules
  • Excluded property
  • UK residential Property
  • Relevant Loans
  • Close company interests
  • Traps for Trustees
  • Specialty Debts and Situs
12:30 - 1:00 pm

Offshore Limited Partnerships and Offshore Income Funds

  • Offshore Income Funds
  • Are offshore limited partnerships mutuals
  • Transparent funds
  • German limited partnerships
  • Information letters
  • Becoming listed
  • EU exchange
  • Conceptual Problems
  • Termination on Listing
  • The “under-belly” problem
1:00 - 2:00 pm
2:00 - 2:40 pm

Structures and Advice for International Sports Players

  • Up to date view of image rights
  • Up to date view of taxation of football agents
  • Brief consideration of UK international tax considerations –
    • transfer of assets abroad
    • transfer of income streams
    • sale of occupation income
    • transfer pricing
  • Taxation of international sports players in relation to UK tournaments
    • winnings
    • brand receipts
2:40 - 3:05 pm

International Trust Registration

  • The ‘Trust’ concept
  • Uses and benefits of international trusts
  • Criticisms of Trust registration (further consideration of the EU’s Fourth AML Directive and the OECD’s Common Reporting Standard)
  • Problems and pitfalls of Trust registration: complexity and privacy
3:05 - 3:40 pm

The New Residential Property Tax and Update on UK Land Taxes

  • Getting ready for the RPDT
  • Who and what is taxable? It can’t possibly apply to me!
  • What is meant by residential property?
  • Beginning or the end: what next?
  • UK Land Tax Update – tips and traps for 2022
  • Capital allowances, SDLT and the CGT 30 day payment rules…
3:40 - 4:00 pm

Tea Break

4:00 - 4:30 pm

Tax Investigation Tactics - Information Notices

  • Schedule 36 FA 2008
  • Taxpayer Notices
  • Third Party Notices
  • What information or documents are “reasonably required”
  • Rights of appeal
  • Statutory Records
  • Recent Cases
  • Relevance of Domicile
4:30 - 4:50 pm

Trading in Financial Instruments - The Taxpayer Wins At Long Last

  • A discussion of Gill v HMRC in which Imran Afzal successfully acted for the taxpayer
  • Tips on how to prepare for litigation on the question of whether a person transacting in financial instruments is trading for tax purposes
4:50 - 5:10 pm

Solving Interest Relief At Source Problems

  • Update of HMRC’s approach to identifying the source of interest – foreign or UK
  • Brief review of the Greek Bank case and Ardmore
  • Developing a strategy
    • commercial reality
    • practical approach
    • relevance of residence of debtor and creditor
    • where would enforcement take place?
    • structuring the documentation
    • advising generally
5:10 - 5:40 pm

Foundations, Anstalts, Stiftungs etc... - What Does HMRC Make of These Civil Law Institutions?

  • Permanent corporate trustees
  • SDLT relief for Anstalts
  • IHT and foundations
  • The ATED and foundations
  • Golden trusts and foundations
  • Bounce-off stiftungs
  • Critical roles for civilian clients
  • Stiftung and LTD structures
  • Entity classification
5.40 - 5.45pm

Close of Conference