A number of things. As I have a significant contentious tax practice, I get a lot of disclosure, investigation or dispute type work. As an international tax partner, the bulk of this work has some international aspect, either from a residence or domicile position, or in relation to the nature of the underlying business or transaction.
I have been doing a lot of work on the requirement to correct rules, and I am seeing an increase in old style investigations, such those under Code of Practice 9.
If you could make one change to a tax law or practice, what would it be?
The same utopia we’ve all been looking for – simplicity!
What do you know now that you wish you’d known at the start of your career?
In a sense I’ve had two careers: one with HMRC, and a second with the wider profession. I did my CTA after I had left HMRC. If I was to do it again, I would have sat my CTA exams whilst still at HMRC.
Are there any new rules that are causing a problem?
Many, mainly in relation to anti-avoidance. Whilst I understand the concerns around avoidance and the need to counter it, we are seeing more and more anti avoidance legislation or targeted anti-abuse rules (TAAR), drafted in such a way as to cast significant doubt in advisers’ minds.
What should we look out for in 2019?
As a council member of the CIOT and a member of the Management of Taxes Sub-committee and vice president of CFE Tax Advisers, I have been undertaking a lot of work around the recently introduced profit diversion disclosure facility. I expect to see a lot of work during the year in and around the area of economic substance, particularly in relation to the OECD BEPS initiative and specifically avoided permanent establishment and transfer pricing.
I would question the level of understanding of BEPS type issues in the private client world and ask how ready that world is for the challenges therein
Building on the point above, as someone working significantly in the private client space but with a corporate tax background, I would question the level of understanding of BEPS type issues in the private client world and ask how ready that world is for the challenges therein.
Finally, you might not know this about me but…
I used to be a pretty good drummer; I still am but I don’t have the time to pursue that aspect of life. Instead, I spend most of my spare time now on the touchline watching my boys play rugby and football.
A number of things. As I have a significant contentious tax practice, I get a lot of disclosure, investigation or dispute type work. As an international tax partner, the bulk of this work has some international aspect, either from a residence or domicile position, or in relation to the nature of the underlying business or transaction.
I have been doing a lot of work on the requirement to correct rules, and I am seeing an increase in old style investigations, such those under Code of Practice 9.
If you could make one change to a tax law or practice, what would it be?
The same utopia we’ve all been looking for – simplicity!
What do you know now that you wish you’d known at the start of your career?
In a sense I’ve had two careers: one with HMRC, and a second with the wider profession. I did my CTA after I had left HMRC. If I was to do it again, I would have sat my CTA exams whilst still at HMRC.
Are there any new rules that are causing a problem?
Many, mainly in relation to anti-avoidance. Whilst I understand the concerns around avoidance and the need to counter it, we are seeing more and more anti avoidance legislation or targeted anti-abuse rules (TAAR), drafted in such a way as to cast significant doubt in advisers’ minds.
What should we look out for in 2019?
As a council member of the CIOT and a member of the Management of Taxes Sub-committee and vice president of CFE Tax Advisers, I have been undertaking a lot of work around the recently introduced profit diversion disclosure facility. I expect to see a lot of work during the year in and around the area of economic substance, particularly in relation to the OECD BEPS initiative and specifically avoided permanent establishment and transfer pricing.
I would question the level of understanding of BEPS type issues in the private client world and ask how ready that world is for the challenges therein
Building on the point above, as someone working significantly in the private client space but with a corporate tax background, I would question the level of understanding of BEPS type issues in the private client world and ask how ready that world is for the challenges therein.
Finally, you might not know this about me but…
I used to be a pretty good drummer; I still am but I don’t have the time to pursue that aspect of life. Instead, I spend most of my spare time now on the touchline watching my boys play rugby and football.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
