Rory Mullan

Barrister

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

St Columb’s College, Derry; Magdalene College, Cambridge (MA).