32nd Annual Oxford Residential Seminar in Conjunction with Tax Chambers, 15 Old Square, Lincoln’s Inn

Chair: Robert Venables Q.C.

Date: 01/10/2014 - 03/10/2014

Price: £975.00 + VAT


32nd Annual Oxford Residential Seminar   



In Conjunction with Tax Chambers, 15 Old Square, Lincoln’s Inn


Wednesday 1st to Friday 3rd October  

Merton College, Oxford  

The aim of this year’s residential seminar is once again to examine, in the congenial atmosphere of an historic Oxford College, practical solutions to the ever changing fiscal complications to modern life. In addition to talks, a key feature of the Conference is the group sessions, in which case studies and problem papers are considered.

Topics include:

Fisher v HMRC developments in Transfer of Assets Abroad

New Partnership rules

Remittances by borrowing with foreign income/gains as collateral

The Taxation of Pensions Bill (August 2014)

Residential Property

VAT and Land

IHT on Settlements

2014 has seen attacks emanating from HMRC on rule of Law, the Rules of Natural Justice, the Separation of Powers and Human Rights. The aim is clearly to put HMRC above the law, to bi-pass the courts, to raid our bank accounts, to gag legal advisers, and to imprison the innocent.

Never since the Glorious Revolution of 1688 has there been an attack by the Executive branch of the government in this country on the historic rights and privileges of the British people.

Taxpayers and their advisers must be more vigilant than ever to defend themselves and their hard-won and hard-preserved liberties. 



Robert Venables Q.C. (Chairman)  

Stephen Brandon Q.C.  

James Kessler Q.C.  

Amanda Hardy  

Patrick Cannon  

Rory Mullan  

Setu Kamal 

Harriet Brown 

Oliver Marre 

Etienne Wong  

All of the above are barristers practising at:  

Tax Chambers

15, Old Square

Lincoln’s Inn

London WC2A 3UE.

Senior Clerk: Tony Hall. +44(0)20 7242 2744.


Provisional Timetable  

Wednesday 1st October  

12.00   Registration Begins 

13.00 Lunch Merton College  

14.00 Chairman’s Introduction  

To include brief reference to some Finance Act 2014 and other recent changes not specifically covered in other talks

 14.05 The Attack on The Rule of Law - Robert Venables Q.C.

The Fourfold Attack on the Rule of Law, the Rules of Natural Justice, the Separation of Powers and Human Rights - Putting HMRC Above the Law - HMRC As Prosecutor, Judge and Jury - Guilty Until Proved Innocent and Guilty Even Though Proved Innocent - HMRC Powers to Bi-pass the Courts - HMRC Powers to Gag Barristers and Other Advisers - Gaoling Inadvertent and Other Non-fraudulent Taxpayers - Attacks on Charities - Suggested Lines of Defence - DOTAS Revisited 

14.45 Tax Avoidance, Professional Risk and Litigation - Patrick Cannon 

Civil and criminal liability for professional advisers – Mehjoo, R v Eric Evans and others and Mr and Mrs “B” · GAAR update - Developments in penalties and investigations into tax schemes - FA 2014 changes: “High risk” promoters and accelerated payment procedures - “Follower notices”: distinguishing one scheme from another 

15.25 Challenging Follower Notices and Accelerated Payments - Rory Mullan 

Available routes of challenge - Judicial review as an alternative to appeals - Impact of Human Rights Law 

16.05 Discussion Session with Tea 

16.20 The Key to VAT & Land - Etienne Wong

The default position (exempt) – the zero-rated exceptions – the reduced rate exceptions – the standard rated exceptions – the option to tax – disapplication of the option to tax – the capital goods scheme – transfer of a business as a going concern – trusts – the land-related place of supply rules" 

 17.00  - 18.00 Introduction to Problem Papers  

The panel will discuss the problem papers and give some hints as to some possible solutions which might be explored.

19.00 Pre-dinner drinks and dinner in the Great Hall


Thursday 2nd October  

09.30 Chairman’s Introduction 

09.35 Partnerships - Stephen Brandon Q.C. 

Finance Act 2014 Changes - Limited Liability Partnerships and Deemed Employment: Circumventing the New Rules - Partnerships with Non-Individual Partners: Circumventing the New Rules 

10.20 Tax Treatment of Residential Property - Oliver Marre 

Changes to CGT Principal Private Residence relief in Finance Act 2014 - An end to CGT PPR elections? - Extension of CGT on residential property to non-residents - Extension of ATED - Extension of the SDLT 15% band - A Mansion Tax? - IHT

 11.05 Discussion Session with Coffee

 11.20 Residence and Domicile - Setu Kamal

 The New Statutory Residence Test - Recent Case Law: Daniel v. HMRC - Full-time Working Abroad - Practical Advice on How to Establish and Non-UK Residence - Double Taxation Relief and Current Position of Treaty Override - Recent Developments on Taxation of Non-UK Domiciliaries - Remittances by borrowing with foreign income/gains as collateral

12.05 Taxation of Interest and Transfer of Assets Abroad - James Kessler Q.C. 

 Where is the source of interest post Perrin v HMRC and Ardmore v HMRC - Why does it matter?  Relevance to situs of debt-claims for IHT tax and CGT - EU Savings Directive Recent Developments - OECD Project on BEPS - Proposed criminalisation of non-fraudulent failure to declare offshore interest - EU law defence to Transfer of Asset Rules - Status of Gibraltar - Motive of defence- Multiple transferors

 13.00 Lunch

 15.00 Pensions - A New Dawn: Flexibility v. Liberation- Amanda Hardy

 Flexibility - FA 2014 - Individual Protection IP14 - Fixed Protection FP14 - Changes to Capped and Flexible Drawdown - Changes to Trivial Commutations and Taxed Lump Sums.  Flexibility - FA 2015 - FA 2015 an analysis of the draft Taxation of Pensions Bill published on 6th August 2014 - Complete Freedom of Drawdown (Subject to Marginal Rates) - "Free and Independent Advice" - the Implications - QNUPS - the Future -  Liberation - FA 2014 - What Does it Encompass - Changes to Registration/de-registration -  the "Fit and Proper Persons Test" - Who Qualifies ? -  What is the "Purpose of the Scheme" - the New Statutory Requirement Increased HMRC Information and Penalty Powers 

 15.45 The consultation on relevant property trust charges – a fairer way of calculating tax? - Harriet Brown

The problems with the existing provisions - Purpose of the proposed changes - How the proposed changes work - Responses to the consultation - Dealing with existing trusts - What to do now to prepare for the new legislation

 16.30 Discussion Session with Tea

 16.45 - 18.00 Discussion of Problem Papers in Groups

 19.15 Pre-dinner Drinks

 19.45 Gala Dinner (black tie Optional) in the Great Hall

 Guest Speaker: Nicholas Paines QC, Law Commissioner and deputy High Court Judge.


 Friday 3rd October

 09.30 Continuation of Discussion of Problem Papers in Groups

 10.45 Discussion Session with Coffee

 11.00 Discussion of Problem Papers in Plenary Session and Questions to Speakers

 1.00  Lunch

 Post Lunch Close of Seminar



£975 per delegate plus VAT (£195) = £1,170  (to include course notes, accommodation, meals and wines.)  


For application and conditions please contact:  

Key Haven Publications Ltd, PO Box 669, Oxford OX3 3AU Tel: 01865  

352121;  Fax: 01865 351081; E-mail:  

                     Key Haven Publications Ltd Terms and Conditions Conferences 

Cancellations: Those confirmed in writing 21 days prior to the Seminar qualify for a full refund, subject to a £100 administration fee. Cancellations within 21 days prior to the Seminar do not qualify for a refund, although substitutions  will normally be allowed at Key Haven’s discretion, subject to a £50 administration fee. 

Disclaimer: Key Haven Publications Ltd  reserves the right to change speakers or the programme for reasons beyond its control or on account of changes in the law.

Nothing in the talks or discussions or the notes prepared for delegates constitutes legal advice. They are simply and expression of the speakers' views put forward for the consideration and discussion. No action should be taken nor omitted in reliance on them but independent professional advice should be taken in every case. Neither the speakers nor Key Haven Publications Ltd accept any legal responsibility for them.  

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