CPD Hours Level
Conference expert panelInformation 6 UpdateInformation
SRA Competency B


This conference covers a wide range of topical issues including an analysis of the changes introduced by the 2019 Finance Act through to profit fragmentation and the diversion of profits outside the UK and the future changes to the way relief will be given for capital losses.

Conference Agenda

This conference will cover the following topics:

9.30am - 10.15am: Taxation of IP - Update

Anne Fairpo, Temple Tax Chambers

The government has repeatedly stated that technology (and therefore intellectual property) is the key to the future of the British economy. This session looks at some recent changes to the taxation of intellectual property within the U.K. and a refresher on claiming intellectual property tax reliefs.

  • FA2019 changes
    • Amortisation of goodwill reintroduced: what qualifies, and limitations on the relief
    • Degrouping updated: when the charge will, and will not, disappear
    • Overseas receipts from IP: points to watch for UK subsidiaries of international groups
  • Claiming incentives - pitfalls & possibilities
    • SME R&D relief
    • RDEC
    • Patent box

10.15am - 11.00am: Denying Tax Relief for Funding Costs on Unallowable Purposes

Nikhil Mehta, Gray's Inn Tax Chambers

The Loan Relationships legislation contains a broad anti-avoidance provision denying interest relief where there is an unallowable purpose.

This provision has been under scrutiny in several recent cases which will be discussed.

The session will cover:

  • Whose purpose is it?
  • The scope for apportionment between allowable and unallowable purposes
  • The burden of proof
  • The role of tax advisers
  • Practical steps to build a strong case for relief

11.15am - 12.00pm: Profit Anti-Fragmentation Regime

Jeremy Mindell, Primondell Ltd

The Finance Act 2019 introduced new rules to counter profit fragmentation and the diversion of profits outside the UK. The major departure from previous legislation is the fact that there is no exemption for small and medium sized companies.

The new rules will open up a new category of companies for investigation who for the first time will need to understand transfer pricing and diverted profits tax rules.

The session will cover:

  • Details of the new rules
  • Which companies are likely to be affected?
  • How HMRC will target companies
  • Practical measures that companies can adopt

12.00pm - 12.45pm: Capital Losses: The Next Loss Reform

Sarah Squires, Old Square Tax Chambers

At Budget 2018, the government announced its intention to change the way relief is given for capital losses from April 2020.

The proposals include extending the corporate loss restriction to capital losses. With a consultation on delivery only, it seems very likely that next year will see significant changes to how relief for capital losses is given.

This session looks at what the government is currently proposing - and how this new loss reform fits with the changes made to corporate income losses in 2017 (CILR).

  • Reform of capital loss relief - the proposals
  • Adapting CILR: applying the deductions allowance across all losses
  • Transitional rules
  • Commencement and anti-forestalling

12.45pm - 1.00pm: Questions on Morning Session

2.00pm - 2.50pm: Transfer Pricing & Tax Avoidance

Ben Symons, Field Court Chambers

This session covers the tax planning techniques that companies use to shift profits from high tax jurisdictions to low tax jurisdictions. It will deal with the following topics:

  • An overview of transfer pricing
  • The major planning techniques by which multi-national groups organise their corporate structures to shift profits from high tax jurisdictions to low tax jurisdictions
  • Executions risks that companies face implementing these structures
  • Comprehensive analysis of how the Diverted Profits Tax can apply
  • Potential challenges to the Diverted Profits Tax using double tax treaties or EU right to freedom of establishment

2.50pm - 3.40pm: Use of Corporate Losses

Jeremy Mindell, Primondell Ltd

The Finance Act 2017 radically changed the way that corporate income losses could be utilised. These new rules are also being introduced for chargeable losses.

This session looks at:

  • How the rules have worked in practice
  • Administrative requirements to claim losses
  • The interaction with other claims e.g. capital allowances and interest
  • Tax planning guidance

3.55pm - 4.45pm: Corporate Tax Workshop

Ben Symons, Field Court Chambers

This practical session will explore a range of corporate tax problem issues and enable delegates to examine, discuss and report back with their suggested solutions.

4.45pm - Close: Questions & Answers

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Conference | 30.10.2019

London | 9:30am - 5:15pm

Corporate Tax - 2019 Annual Conference

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9:30am - 5:15pm
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