Rebecca started her tax career in 2001 advising owner managed businesses on a range of technical issues and subsequently wrote a book on corporation tax in 07/08 whilst working in the tax department of JP Morgan, where she expanded her corporation tax knowledge and experience of the issues large corporates face.
TAX PRACTICE
Rebecca’s tax practice now includes advising and representing all sizes of corporates and HMRC on the full array of income and chargeable gains issues.
Examples of current issues she has advised large corporates on include:
Advice to the Government of India in its arbitration against Cairn Energy in the Hague, brought by Cairn Energy under the UK-India Bilateral Investment Treaty (“BIT”). Capital gains tax was charged under the Income Tax Act on a disposal of shares in a group reorganisation in 2006. The Indian Income Tax Department attached a 10% shareholding in a subsidiary, CIL as a result of the tax liability. The arbitration claims ran to several billion pounds.
Whether restructuring arrangements in a UK sub-group involve a main purpose of obtaining a tax advantage for the debtor company (including advice on Travel Document Services in the Court of Appeal and the FTT case of AH Field)
Whether a release of a loan in a liquidation of connected company is tax neutral under the loan relationship rules as amended by FA 2015
The application of the post-2013 controlled foreign companies legislation to a large multi-national drinks group
Application of the “Management and control” test for UK residence of companies
Whether a company has a permanent establishment in the UK for the purposes of the application of the model Treaty, and other applications of treaties
Group relief issues, such as planning to relieve trapped losses brought forward, capital loss relief, non-trading loan relationship deficits, share ownership structures
Substantial Shareholding Exemption issues in a sale of a manufacturing group of part of its trade, eg whether capital held for use in the trade, other farming activities of the group.
Potential application of the GAAR to a large variety of planning arrangements
The diverted profits tax (see also an article written on Diageo)
Corporate property ownership structures and associated VAT and SDLT issues
CONTACT DETAILS
Please contact the clerks at Devereux Chambers on 0207 353 7534 to discuss how Rebecca can help with your requirements or send an e-mail outlining the issues to [email protected] marked for her attention.