42nd Annual Oxford Four-Silk Fourteen-Speaker Residential Seminar

Chair: Robert Venables K.C.

Date: 24/09/2024

Price: £1,325.00 + VAT




42nd Annual Oxford Four-Silk Fourteen-Speaker Residential Seminar

Tuesday September 24th - Thursday September 26th 2024  

   Merton College, Merton St, Oxford.



Full price  £1,525 per delegate plus VAT (£305.00) = £1,830



For bookings made and paid for before August 5th 2024 

 £1,325 per delegate + VAT (£265) = £1,590


(to include course notes, accommodation, meals and wines.)



 Robert Venables K.C. (Chairman)

James Kessler K.C.

Rory Mullan K.C.

Philip Simpson K.C.

Sarah Squires

Harriet Brown

Ben Symons

Patrick Boch

Mary Ashley

Ross Birkbeck

Rebecca Sheldon

Shane O’Driscoll

Chris Vallis

Shanzé Shah


The speakers are all practising barristers.  They are all members of Old Square Tax Chambers,15 Old Square, Lincoln’s Inn W2A 3UE: Website:, Contact:




TUESDAY September 24th


12.00 Arrival and Registration


13.00 Lunch Merton College


14.00 Chairman’s Introduction


14.10 What to do with Individuals' UK Real Property Portfolios - Ross Birkbeck


Long-Term Structures: Incorporation?  Partnership  ?  Limited liability Partnership ? Use of IHT and CGT EBT provisions? - Tax Considerations and Risks"


14.50 Withholding tax post -Hargreaves Property Holdings - Sarah Squires


The obligation to withhold - yearly interest (Lehman Administrators/Hargreaves Property Holdings) - key exemptions: UK-UK and treaty relief - "beneficial entitlement" - other issues


15.30 Post-death variations to estates - Mary Ashley


Tax consequences – potential pitfalls – options where there are minor beneficiaries


16.10 Discussion Session with Refreshments


16.25 The Concept of Trading - Rebecca Sheldon


Fundamental principles and recent case law- When does a trade commence? - How it applies in distinct areas of tax which may come up for private clients: Income tax vs CGT treatment; Business property relief for IHT; Business asset disposal relief for CGT; Gift hold over relief for CGT; If a property trade is being carried out, the potential implications for principal private residence relief


17.05The remittance basis - Rory Mullan K.C.


What is left for the remittance basis after changes to the non-dom rules and the election? - Recent cases: Segal, D'Angelin and Alimahomed - Other issues


17.45 Estoppel by Convention within the Context of Tax Litigation - Christopher Vallis


What is it and how did it come about? - The test for estoppel by convention -  The Tinkler decision -  More recent tax decisions (York) - How might it be useful to taxpayers?


18.25 Approx Close of Formal Proceedings for the Day


19.00  Pre-dinner Drinks


19.30 Dinner in the Great Hall




09.30 Chairman’s Introduction


09.35 Partnerships, Limited Partnerships and Limited Liability Partnerships - Robert Venables K.C.


Non-tax law: distinctions in reality - HMRC myths.  Distinctions in general tax treatment.  Taxation of income: income tax treatment including current law on basis periods - corporation tax treatment of income - deemed partners - mixed partnership rules - income streams rules.  Capital gains tax treatment - HMRC published confusion.  Stamp duty land tax: special irrational rules for partnerships including property investment partnerships.


10.20 Employee Ownership Trusts - Philip Simpson K.C.


What is an employee ownership trust - When is an employee ownership trust a useful thing - What are the tax benefits - What conditions must be met - What are the tax traps


11.00  Discussion Session with Refreshments


11.20  Double Tax Agreements For UK Residents including Non-UK Domiciliaries - Harriet Brown


 How treaties can take the sting out of changes to the taxation of non-UK domiciliaries - Treaty residence vs statutory residence test - DTT provisions for individuals: OECD Model - CDOT treaties with the UK (Gibraltar, Guernsey, Isle of Man and Jersey) - EU states: Cyprus, Greece, Ireland, Italy and Cyprus-UK treaties - US Treaty


12.00 - 12.45 Changes to UK non-dom rules – an Irish alternative? - Shane O’Driscoll


Introducing some of the Irish tax rules and tax considerations for the internationally mobile


13.00 Lunch


16.30  Discussion Session with Refreshments


16.45 The Unallowable Purpose (CTA 2009 Section 441) - Patrick Boch


The rule - Case law, including Kwik Fit and BlackRock Holdco 5 LLC - Application to increase of interest under an existing loan - Solutions


17.30 Civil law trust equivalents: usufruct, substitution fidéicommissaire, libéralité  - James Kessler K.C.


UK tax treatment: IHT, IT, CGT; planning implications


18.15 Approx Close of Formal Proceedings for the Day


19.15 Pre dinner drinks


19.45 Gala Dinner Merton College (Black-Tie entirely Optional) in the Great Hall




09.30 Chairman’s Introduction


09.35 CGT roll-over relief on replacement of business assets - Shanzé Shah

Basics - Do the assets need to be used for the purposes of a trade? Does the taxpayer need to be carrying on a business? - Qualifying assets - what is meant by "occupied (as well as used) for the purposes of the trade"?


10.20 Offshore Trusts - Ben Symons


Correctly structuring loans to and from offshore trusts to minimise income tax and inheritance tax;  the perils of the transfer of assets abroad provisions in relation to offshore trusts."


11.00  Discussion Session with Refreshments


11.15 Questions to Speakers


12.45 Lunch


14.00 Close of Seminar







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 £250 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, subject to a £100 administration fee.