Corporate Tax - 2024 Conference

Introduction

Returning to London for 2024, this annual conference examines a range of currently topical subjects ranging from the company and employee ownership trusts through to transfer pricing.

With its panel of leading corporate tax experts, this conference, chaired by Philip Ridgway, will provide you with a timely update on corporate tax matters.

Conference Agenda

This conference will cover the following:

9.30am - 10.15am: Claims Under the Tax Covenant: Notice Provisions

Philip Ridgway, Temple Tax Chambers

This session will discuss the following:

• What does the notice provision actually say?
• Time limits and conditions precedent to claiming
• An examination of different clauses
• Recent cases

10.15am - 11.00am: Employee Ownership: What is it Good For?

Pete Miller, Jerroms Miller

The evidence suggests that employee-owned businesses achieve higher productivity and greater levels of innovation and are more resilient to economic turbulence. They also have more engaged, more fulfilled, and less stressed workforces. FA 2014 introduced a relief from capital gains tax for sales of shares to employee ownership trusts. Why did this happen? How do you qualify for relief? And is it all too good to be true?

This session will cover:

• The policy background
• The reliefs
• Qualifying conditions
• Disqualifying events
• Proposed changes to include the latest on EOTs

Morning break for refreshments

11.15am - 12.00pm: MBOs - Current Issues

Pete Miller, Jerroms Miller

Management buyouts are a tried and tested method of passing on ownership of a business to an existing or incoming management team.

However, in recent times we have witnessed HMRC’s changing stance on providing clearances on these transactions depending on the nature of the deal.

This session will cover the main issues we have encountered in obtaining clearance, such as:

• Drafting a strong commercial rationale to support the transaction
• Utilising personal investment companies for tax efficiency purposes
• The effect of an MBO on existing EMI option schemes
• Application of transactions in securities rules
• Stamp duty issues arising from MBO transactions
• Accounting for MBOs

12.00pm - 12.45pm: Main Purpose Tests: What Recent Cases Tell Us

Sarah Squires, Old Square Tax Chambers

Various tax provisions now include main purpose tests and over the last year judges have had to consider the application of this test across various regimes (such as loan relationships, roll over relief and transaction in securities).

This session will cover:

• Recent cases (Euromoney, Kwikfit and Allam)
• How the main purpose test is likely to apply in practice

12.45 - 1.00pm: Questions

Lunch break

2.00pm - 2.50pm: W&I Insurance Backed M&A Deals - Tax

Fionnuala Lynch, McCarthy Denning

Warranty and Indemnity Insurance (W&I Insurance) backed M&A deals are now standard and this session will cover how W&I insurance is used to cover tax risk in M&A deals.

The session will include:

• The interaction of a typical tax deed with the W&I policy
• The impact on the tax warranties
• How to negotiate the tax section of the W&I policy

Afternoon break for refreshments

3.15pm - 4.00pm: Corporate Debt for Companies in Trouble

Philip Ridgway, Temple Tax Chambers

This session will cover:

• A recap of the normal rules
• The corporate rescue exemption
• Connected parties
• Becoming connected
• Substantial modifications

4.00pm - Close: Questions

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.