Rory advises on a range of diverse tax matters. Some issues which he has dealt with recently include:
Taxation of offshore structures, including the application of the transfers of assets abroad code, the attribution of gains under section 13 TCGA 1992 and the treatment of trust gains under sections 86 and 87 TCGA 1992
Residence and domicile status
Taxation of non-UK domiciled persons and those who are deemed to be UK domiciled
Entrepreneurs’ relief and how to secure its availability
Accelerated Payment Notices and Follower Notices
The GAAR and its application
Compatibility of direct tax provisions with EU law
The application of the Transactions in Securities legislation.
Employee taxation including the scope of the benefits code, the employment related securities legislation (Part 7 ITEPA 2003) and the disguised remuneration legislation (Part 7A ITEPA 2003)
Issues in VAT
SDLT planning
Inheritance tax planning
Challenging penalty assessments