Join Us - 8 December 2021
Taxation of Offshore Structures:
Location: Live Online
Taxation of Offshore Structures:
What Practitioners Must Know
Location: Live Online
Event Overview
Taxation of Offshore Structures:
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.
Our Speakers
Expertise in depth
David Bloom QC
Barrister (Australia) the best tax silk in the country Commentator to Chambers Asia-PacificDavid Bloom QC
Reasons To Attend
Why You Should
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
Update on Recent Changes
Once again Patrick Soares takes long, serious subjects and reduces them to short, sharp need-to-know gems.
International Transfer Pricing Forum - United Kingdom, Australia and India
Philip Baker QC (United Kingdom), David Bloom QC (Australia) and Porus F Kaka (Senior Counsel, 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.
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
Attracting UK Investment Managers to the UK
Oktavia Weidmann - Author of Taxation of Derivatives, Series on International Tax Vol 52 &
David Southern QC - Author of Taxation of Loan Relationships and Derivatives
- 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
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
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
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
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
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
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…
Tea Break
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
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
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
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