Chair
David Southern, Barrister, 3 Temple Gardens Tax Chambers

Speakers
Patrick Cannon, Barrister at Law, Tax Chambers, 15 Old Square
Chris Hart, Chartered Surveyor, Hart Consulting Ltd
Tony Llewellyn, Partner, Davis Langdon Crosher & James
Andy Richens, Tax Technical Director, Bishop Fleming Accountants
Leigh Sagar, Barrister, New Square Chambers
Antony Timmins, Senior Manager, Real Estate Tax, PricewaterhouseCoopers LLP
Justin Whitehouse, Indirect Tax Partner, Deloitte & Touche LLP

 

Programme

Corporation Tax and Income Tax Aspects of Acquiring Property
• Importance of investment/trading distinction and taxation implications
• Tax efficient financing routes; corporation tax and income tax
• Optimising the utilisation of losses
• Lease premiums and other special tax rules affecting the taxation of property
• Recent developments

Tax Avoidance
• Tax avoidance v tax evasion
• Ramsay and purposive construction
• EDI Services v HMRC – brave new world?
• Disclosure of tax avoidance schemes: 2006 upgrade
• Current SDLT planning issues

Capital Allowances
• Wide application to property
• Principles of operation and benefits to taxpayer
• Qualifying expenditure and initial and writing down allowances
• Application to:
- industrial buildings
- plant and machinery
- agricultural buildings
- flat conversions
• Land remediation relief
• Essential information for acquisitions and disposals
• New rules on leasing of plant fixtures

Stamp Duty Land Tax
• Background to transactions
• Who pays and who gets relief
• Consideration
• Resting in contract, sub-sale and exchanges
• Variable and uncertain rents
• Surrenders, re-grants, sales and leasebacks
• Works as consideration, premiums and assignments
• Compliance – a tax with teeth
• Problem areas in practice

Value Added Tax
• General principles of VAT
• Types of supply, input and output VAT and recovery of input VAT
• Zero rated supplies and residential development
• Property transactions – exempt and standard rated supplies
• Transfer of a Going Concern and property investments
• Demolition, repairs, refurbishment and development
• Avoidance schemes

Capital Gains Tax
• Capital assets or stock in trade – the badges of trade
• Taper relief for owner occupiers and for investors
• Hold-over and roll-over reliefs
• Private residence exemption
- second homes
- planning
• Non-residence

Inheritance Tax
• Scope of inheritance tax: UK and offshore properties; domicile
• The new inheritance tax rules applicable to trusts
• Lifetime gifts with and without reservation of benefit
• Valuation issues: co-ownership
• Business and agricultural property reliefs
• Planning roundup