Stephen Pevsner
Stephen Pevsner is a tax partner and a member of the Private Funds and Private Equity M&A Groups. Stephen's practice covers the broad range of corporate and individual tax advice, with particular emphasis on private fund formation across a wide range of buyout, debt and infrastructure asset classes, as well as UK and international M&A transactions (often private equity backed). He has wide experience in corporate reorganisations, structured finance, investment funds and new business set-ups, and also advises regularly on a wide range of employee and fund manager incentive arrangements arising from these transactions.
Stephen is a member of the BVCA tax Committee and, according to Chambers UK, he is a notable practitioner in the corporate tax field, praised for "his ability to master the intricacies of tax law and understand the commercial aspects of the deal".
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Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise employees in a tax-efficient way. Broadly, where the relevant qualifying criteria have been met, both the CSOP and EMI schemes allow employees to acquire shares in their employer (or its group) for less … Continue Reading
On 20 July 2022, the UK government published draft legislation for the Finance Bill 2022-2023. Of particular interest are amendments to be made to the qualifying asset holding company (QAHC) regime that was introduced from 1 April this year. The regime is part of the UK government’s attempt to increase the attractiveness of the UK … Continue Reading
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset management limited liability partnership (LLP). BlueCrest is engaged in providing hedge fund investment management services. In … Continue Reading
HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate lending vehicles used by credit funds should be treated as carrying on an investment activity or a trade in the context … Continue Reading
On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share the tax revenue relating to digital services that have led to some jurisdictions, including the UK, introducing … Continue Reading
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer to the sellers under a sale and purchase agreement (“SPA”) of a potential … Continue Reading
Background From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD published guidance on the impact of COVID-19 on double tax treaties (DTTs), including in relation to tax … Continue Reading
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and in the future. In the last year or so, we have regularly written about DAC 6 in our … Continue Reading
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK. While of considerable interest, … Continue Reading
The Office of Tax Simplification (OTS) has published its first report following its review of certain aspects of the UK’s capital gains tax regime requested by the Chancellor in July this year with the specific purpose of identifying opportunities relating to technical and administrative issues as well as areas where the present rules can distort … Continue Reading
In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not contain the level of information required by the provision in the related … Continue Reading
As the UK’s lockdown is relaxed and unemployment figures are expected to continue to rise, the UK Chancellor gave his summer statement announcing measures to stimulate the economy as it recovers from the effects of coronavirus with a clear emphasis on encouraging people to spend money, particularly in the hospitality sector, to try to protect … Continue Reading
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and were charged on to its subsidiary were deductible as expenses of management of the subsidiary under section 1219 of … Continue Reading
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain employment status assessment and, depending on the circumstances, employment tax payment obligations from the worker’s … Continue Reading
In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of taxation. Significantly, the proposal includes an extension to the time limit for reporting information under the new rules on … Continue Reading
In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead an electronic copy (which can be a scanned PDF) should be emailed to HMRC at stampdutymailbox@hmrc.gov.uk. The form … Continue Reading
There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies, particularly where directors are stuck in a different jurisdiction and cannot attend board meetings as they would in normal circumstances. On 7 April, HMRC updated its published guidance to discuss … Continue Reading
Introduction In these testing times the ramifications of COVID-19 continue to be felt in every area of personal and corporate life. With lockdowns announced around the world, including in the UK on 23 March 2020, travel has been severely curtailed and business practices are having to change accordingly. Below we discuss what this means for … Continue Reading
Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key points: The scheme will provide direct cash grants of 80 per cent of individuals’ taxable profits (based on average monthly trading profit … Continue Reading
Earlier this evening the UK Chancellor announced an economic intervention which is “unprecedented in the history of the British state” with measures to support the United Kingdom economy in the midst of COVID-19. Below are the key measures he announced for businesses: The government is setting up a Coronavirus Job Retention Scheme. The scheme will … Continue Reading
Last night (17 March 2020) the UK’s Chief Secretary to the Treasury, Steve Barclay, announced in the House of Commons that the government is postponing the implementation of the changes to the application of the off payroll working tax rules to private sector clients (IR35) from 6 April 2020 to 6 April 2021 to ease … Continue Reading
As we reported in our Tax Talks blog of 8 January, the Government has carried out a review of the implementation of the changes to the private sector IR35 rules. This review has now completed with the Government confirming on 27 February that the extension of the IR35 rules to the private sector will take … Continue Reading
There has been much talk recently about “review and reform” (or abolition) of entrepreneurs’ relief. This seems to have moved a step closer this week with Boris Johnson stating that the Treasury are “fulminating” against it on the basis that it made “staggeringly rich” people “even more staggeringly rich”. The debate about this was kicked … Continue Reading
In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment fund partnerships. The changes covered a number of areas, including requiring a UK partnership that had partnerships amongst its partners … Continue Reading
Upcoming changes to the company share options plan regime
By Stephen Pevsner, Robert E. Gaut, Richard Miller and Emma C. McDonnell on Posted in Tax, UK Tax
HMRC Announces Welcome Changes to the QAHC Regime
By Stephen Pevsner and Philip Gilliland on Posted in Corporate tax, In the news, UK Tax
BlueCrest FTT Decision – Salaried Member Rules and Asset Managers
By Stephen Pevsner, Robert E. Gaut, Catherine Sear and David M. Ward on Posted in In the news, Tax Policy, UK Tax
HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles
By Robert E. Gaut, Stephen Pevsner and David M. Ward on Posted in Corporate Taxation, UK Tax
A step closer to agreement on taxation of the digital world
Court of Appeal overturns High Court and holds that tax claim notice was valid
By Stephen Pevsner and Katerina Heal on Posted in UK Tax
COVID-19: OECD updates its guidance on residence and permanent establishments
By Stephen Pevsner and Philip Gilliland on Posted in Coronavirus, Corporate tax, In the news, UK Tax
Narrowing of UK intermediaries’ DAC 6 reporting requirements
By Stephen Pevsner, Richard Miller and Philip Gilliland on Posted in UK Tax
Court of Appeal decides that Jersey companies were UK tax resident
By Katerina Heal and Stephen Pevsner on Posted in UK Tax
New OTS report recommends changes to UK’s capital gains tax regime
By Stephen Pevsner and Rebecca Wallis on Posted in In the news, Tax Reform, UK Tax
High Court decision highlights importance of ensuring claims notices include required information
By Stephen Pevsner and Rebecca Wallis on Posted in UK Tax
Chancellor’s Summer Statement focuses on hospitality sector
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Advisers’ fees non-deductible where management decisions made by parent company
By Philip Gilliland and Stephen Pevsner on Posted in Corporate tax, UK Tax
IR35 extension to private sector – Finance Bill 2020 amendment on territorial scope
By Philip Gilliland and Stephen Pevsner on Posted in Corporate tax, In the news, UK Tax
COVID-19: DAC 6 reporting delayed
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, Corporate tax, UK Tax
COVID-19: interim measures on stamp duty announced by HMRC
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
COVID-19: HMRC Announces its Approach to Company Residence
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
COVID-19: UK Tax Residence for Companies and Individuals
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
COVID-19: UK Chancellor announces measures to support the self-employed
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Coronavirus: UK Chancellor announces unprecedented measures to support the British economy
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
IR35 overhaul postponed until 6 April 2021
By Philip Gilliland and Stephen Pevsner on Posted in Coronavirus, In the news, UK Tax
Government confirms private sector IR35 rules will be introduced in April
By Philip Gilliland and Stephen Pevsner on Posted in In the news, UK Tax
Latest on Abolition of Entrepreneurs’ Relief
By Stephen Pevsner on Posted in UK Tax
Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships
By Katerina Heal and Stephen Pevsner on Posted in Partnership Taxation, UK Tax
