Offshore Tax Planning and Tax Planning for Foreign Domiciliaries

Offshore Tax Planning and Tax Planning for Foreign Domiciliaries

A Triple Silk Afternoon Seminar at the Law Society's Hall, London

Chair: Robert Venables K.C.

Date: 19/06/2024

Price: £600.00 + VAT

Key Haven Publications Ltd 







Wednesday June 19th 2024  The Law Society, 113 Chancery Lane, London WC2A 1PL




Robert Venables K.C. (Chairman)

James Kessler K.C.

Rory Mullan K.C.


The speakers are all practising barristers and members of Old Square Tax Chambers,15 Old Square, Lincoln’s Inn WC2A 3UE: Website:, Contact: or 020 7242 2744


The Need for Action


Few doubt that by the end of 2024 the United Kingdom will have a Labour government.  The  Labour Party has cleverly stated very little about its intentions re taxation.  Yet it is obvious to any intelligent person that taxes will need to be raised even further.


While it was proposed in the Budget Speech in March to introduce wide changes to the taxation of United Kingdom resident foreign domiciliaries as from 2025/26, few believe the present government will be in a position to effect such changes. 


It is proposed to counter by legislation the recent taxpayer success in the Supreme Court in Fisher v HMRC.  This is a timely occasion to review how the law stands on the Transfer of Assets Abroad Provisions.




13.00 Arrival and Registration with Refreshments


13.45 Chairman’s Introduction


13.50 The Transfer of Assets Abroad Provisions Post Finance Act 2024  - Robert Venables K.C.


How the Provisions work: the separate heads of charge.  What do they catch and what do they not catch? 


The Supreme Court decision in Fisher and others v HMRC [2023] UKSC 44 - what did the case actually decide? - what does it indicate about current Judicial thinking?


Multiple transferors - indirect transferors - the motive defences - transfers by non-UK residents - the EU defence - avoidance of foreign taxation as a commercial motive - double taxation convention protection


The current Finance Bill proposals


14.35   Pre-UK Arrival Planning for Future Non-UK Residents - Rory Mullan K.C.


Impact of the new rules - Non-UK and UK domiciliaries – previously domiciled residents - what can they do? – what still works and what doesn’t? – Dealing with uncertainty


15.15   Discussion Session with Refreshments


15.30  What should Foreign Domiciled United Kingdom Residents be doing as of June 2024?  -  James Kessler K.C. 


The 2024 spring Budget proposals - possible changes in the law by a Labour government - income tax - capital gains tax - inheritance tax - forestalling generally


16.15   Questions to Speakers and Panel Discussion


16.45   Close of Seminar




£600 per delegate plus VAT (£120.00) = £720


(to include course notes and refreshments)




For application and conditions please contact:


Key Haven Publications Ltd, PO Box 669, Oxford OX3 3AU Tel: 01865 352121;






Those confirmed in writing 30 days prior to the Seminar qualify for a full refund,

subject to a £50 administration fee. Cancellations within 30 days prior to the Seminar do not qualify for a refund, although substitutions will normally be allowed at Key Haven’s discretion.