It was a complete accident. Back in the early 1980s, I was a struggling young barrister and my fiancée was working in HR at KPMG (then Peat Marwick Mitchell). She suggested that I chat to someone there about opportunities in the tax world, and to her horror they offered me a job. I thought it sounded interesting and decided to give it a whirl. I stayed there for 30 years before moving to my current firm.
You have extensive experience in corporate and international tax, with a particular focus on real estate. Comment on a topical issue.
We are seeing an increased interest in the use of REITs as investment vehicles, even joint ventures. As some of the other vehicles used for real estate investment face more challenges, particularly from some of the BEPS initiatives, REITs are emerging as an interesting alternative both in the UK and elsewhere. Recent changes to the rules in the UK and other jurisdictions have tended to help make REITs more flexible and attractive for this purpose.
Aside from your immediate colleagues, whom in tax do you most admire?
The late Professor John Tiley was my tutor at Cambridge, and pioneered the study of tax law in this country at a time when it was hardly recognised as an academic discipline. As tax becomes a more and more complex and intrusive part of all our lives, proper academic study of its underlying principles has never been more important. John’s legacy internationally in this field cannot be overstated. He was also a lively and engaging companion. He is much missed.
What advice would you give to someone new to the profession?
There is no substitute for really understanding your clients and their business. If you do not understand what they are trying to achieve in a transaction or business venture, you will not be able to give them the practical advice they require. It is also better to get too much information from your client rather than too little, as long as you learn how to sift it and identify the bits which really matter.
If you could make one change to tax, what would it be?
Property taxes are a real mess in this country and exacerbate many of the problems in the property market. I would reduce SDLT to 1 or 2% on all transactions and recast council tax as a proper tax on current values. Business rates are a crippling cost and in need of a major overhaul.
BEPS is meant to deliver better transparency, increased certainty and predictability, and coherence of international rules. Are you optimistic?
Yes and no. I think that we may well end up with a new set of rules which are applied more consistently across a number of countries. The downside of this is that we end up with a one size fits all approach, less able to be applied flexibly to take account of different industry or market conditions. For example, the BEPS actions on treaty abuse and interest deductions are being designed primarily to fit multinational operating businesses and may not adapt well to the real estate and infrastructure investment world. There is a risk that these provisions will reduce the flow of capital into these essential areas.
You might not know this about me...
I am a serious music lover, particularly early music. I spend a lot of my spare time involved with charities for musically gifted children. However, I am really happiest when I am in a small choral group singing the wonderful music of the renaissance.
It was a complete accident. Back in the early 1980s, I was a struggling young barrister and my fiancée was working in HR at KPMG (then Peat Marwick Mitchell). She suggested that I chat to someone there about opportunities in the tax world, and to her horror they offered me a job. I thought it sounded interesting and decided to give it a whirl. I stayed there for 30 years before moving to my current firm.
You have extensive experience in corporate and international tax, with a particular focus on real estate. Comment on a topical issue.
We are seeing an increased interest in the use of REITs as investment vehicles, even joint ventures. As some of the other vehicles used for real estate investment face more challenges, particularly from some of the BEPS initiatives, REITs are emerging as an interesting alternative both in the UK and elsewhere. Recent changes to the rules in the UK and other jurisdictions have tended to help make REITs more flexible and attractive for this purpose.
Aside from your immediate colleagues, whom in tax do you most admire?
The late Professor John Tiley was my tutor at Cambridge, and pioneered the study of tax law in this country at a time when it was hardly recognised as an academic discipline. As tax becomes a more and more complex and intrusive part of all our lives, proper academic study of its underlying principles has never been more important. John’s legacy internationally in this field cannot be overstated. He was also a lively and engaging companion. He is much missed.
What advice would you give to someone new to the profession?
There is no substitute for really understanding your clients and their business. If you do not understand what they are trying to achieve in a transaction or business venture, you will not be able to give them the practical advice they require. It is also better to get too much information from your client rather than too little, as long as you learn how to sift it and identify the bits which really matter.
If you could make one change to tax, what would it be?
Property taxes are a real mess in this country and exacerbate many of the problems in the property market. I would reduce SDLT to 1 or 2% on all transactions and recast council tax as a proper tax on current values. Business rates are a crippling cost and in need of a major overhaul.
BEPS is meant to deliver better transparency, increased certainty and predictability, and coherence of international rules. Are you optimistic?
Yes and no. I think that we may well end up with a new set of rules which are applied more consistently across a number of countries. The downside of this is that we end up with a one size fits all approach, less able to be applied flexibly to take account of different industry or market conditions. For example, the BEPS actions on treaty abuse and interest deductions are being designed primarily to fit multinational operating businesses and may not adapt well to the real estate and infrastructure investment world. There is a risk that these provisions will reduce the flow of capital into these essential areas.
You might not know this about me...
I am a serious music lover, particularly early music. I spend a lot of my spare time involved with charities for musically gifted children. However, I am really happiest when I am in a small choral group singing the wonderful music of the renaissance.
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