Well, I had to choose a corporate-related seat when I was doing articles. Most of corporate wore braces; I didn’t have any and the corporate tax group didn’t wear them so joining tax seemed to suit.
Who, in tax, do you most admire?
I suppose one of the formative influences was John Overs, when I was at Berwin Leighton. He taught me a lot, and I gained my confidence in tax with him. As regards Counsel, David Goldberg and David Milne are always very insightful in their comments.
What advice would you give to someone entering the profession?
I would say that with very complex rules you’re not going to get to grips with all of it immediately; be patient; don’t get to a position where you fail to see the wood for the trees, in other words, always value a common-sense approach however technically difficult the subject matter; and know your area of competence.
If you could make one change to the UK tax code what would it be?
II would alter the rules in the Finance Act 2012, which impose the new charge to SDLT on high value residential property. I would move the requirement that a property developer has to carry on a development business for two years prior to acquiring an asset in order to fall outside the 15% charge to SDLT. I think that would be helpful because it’s currently very difficult to get certainty of treatment for special purpose vehicles which are newly set up to undertake mixed development, for example, which has a residential element and where no avoidance intention exists.
What are your views on HMRC?
It is to be congratulated, for helping make the UK tax rules more competitive – for instance, on revisiting the CFC rules and for seeking input from both professionals and multinationals. But I do think – and this may not be entirely the fault of HMRC – that there’s more political pressure now on the tax environment, particularly in terms of anti-avoidance legislation. One wonders whether some of the very specific anti-avoidance rules that have come in have been thoroughly thought through.
What’s your view on the GAAR?
I had no issue with the Graham Aaronson formulation of it, which sensibly placed its focus on egregious tax planning and had with a limited number of taxes falling within its remit, with SDLT and IHT tax not immediately on the agenda. But the genie is now out of the bottle in that regard and clearly its ambit has been widened. I do have a concern with taxpayer certainty. It’s one thing to bring in a GAAR that is closely aligned to the self-assessment process, but I really don’t know how that would work in an IHT context, for example.
What’s the future direction for Taylor Wessing’s tax team?
We’re increasingly looking at international tax work; we’ve opened up new offices in Singapore and Eastern Europe. In a competitive and, to some extent, contracting the UK domestic market it’s increasingly important to look to export tax services.
You might not know this about me but ...
I once took a three-year gap from tax immediately after articles and spent those years, amongst other things, in an entirely fruitless study of the poetry of Wallace Stevens.
Well, I had to choose a corporate-related seat when I was doing articles. Most of corporate wore braces; I didn’t have any and the corporate tax group didn’t wear them so joining tax seemed to suit.
Who, in tax, do you most admire?
I suppose one of the formative influences was John Overs, when I was at Berwin Leighton. He taught me a lot, and I gained my confidence in tax with him. As regards Counsel, David Goldberg and David Milne are always very insightful in their comments.
What advice would you give to someone entering the profession?
I would say that with very complex rules you’re not going to get to grips with all of it immediately; be patient; don’t get to a position where you fail to see the wood for the trees, in other words, always value a common-sense approach however technically difficult the subject matter; and know your area of competence.
If you could make one change to the UK tax code what would it be?
II would alter the rules in the Finance Act 2012, which impose the new charge to SDLT on high value residential property. I would move the requirement that a property developer has to carry on a development business for two years prior to acquiring an asset in order to fall outside the 15% charge to SDLT. I think that would be helpful because it’s currently very difficult to get certainty of treatment for special purpose vehicles which are newly set up to undertake mixed development, for example, which has a residential element and where no avoidance intention exists.
What are your views on HMRC?
It is to be congratulated, for helping make the UK tax rules more competitive – for instance, on revisiting the CFC rules and for seeking input from both professionals and multinationals. But I do think – and this may not be entirely the fault of HMRC – that there’s more political pressure now on the tax environment, particularly in terms of anti-avoidance legislation. One wonders whether some of the very specific anti-avoidance rules that have come in have been thoroughly thought through.
What’s your view on the GAAR?
I had no issue with the Graham Aaronson formulation of it, which sensibly placed its focus on egregious tax planning and had with a limited number of taxes falling within its remit, with SDLT and IHT tax not immediately on the agenda. But the genie is now out of the bottle in that regard and clearly its ambit has been widened. I do have a concern with taxpayer certainty. It’s one thing to bring in a GAAR that is closely aligned to the self-assessment process, but I really don’t know how that would work in an IHT context, for example.
What’s the future direction for Taylor Wessing’s tax team?
We’re increasingly looking at international tax work; we’ve opened up new offices in Singapore and Eastern Europe. In a competitive and, to some extent, contracting the UK domestic market it’s increasingly important to look to export tax services.
You might not know this about me but ...
I once took a three-year gap from tax immediately after articles and spent those years, amongst other things, in an entirely fruitless study of the poetry of Wallace Stevens.
90a1d87b-c1b5-43c3-a720-cd324830adee.tmb-editorspic.jpg?sfvrsn=1b2d0a7e_1)
