Stephen advises on a wide range of direct and indirect taxes, including land and buildings transaction tax, stamp duty land tax, VAT, capital allowances, capital gains tax, corporation tax, charity taxes, and employee taxation. He works closely with our Corporate and Real Estate teams to ensure that transactions are implemented in the most tax-efficient manner for clients.
A fully qualified member of the Chartered Institute of Taxation, he is also a Chartered Tax Adviser.
- Advising a Scottish university on stamp duty land tax (SDLT) and land and buildings transaction tax (LBTT) in relation to a shared equity scheme. In particular, he advised on claims for partial charity relief, including the changes made to the SDLT legislation following the Pollen case, and the different rules applying in Scotland.
- Advising an educational charity on a claim for VAT exemption.
- Advising a charity on incorporating a trading subsidiary, enabling recovery of VAT in relation to a charitable property development.
- Advising an international consortium on corporate tax aspects of the acquisition of a substantial gas transmission system.
- Advising a leading developer on tax aspects of a student accommodation development. Including tax-efficient structuring to meet the conditions for VAT zero-rating and to enable the recovery of VAT on construction costs; and advice on land and buildings transaction tax.
- Advising a major property developer on the tax implications of the sale of a former print works for development into a hotel. The transaction involved an innovative forward funding joint venture structure and required detailed advice on VAT, stamp duty land tax, corporation tax and capital allowances.
- Advising a leading aggregates business on a tax covenant claim. The matter involved several novel aspects, including the impact of UK legislation being retrospectively amended due to EU State Aid action being taken against the UK.
- Advising a local authority on VAT, capital allowances and tax structuring for the construction of a new leisure centre.
- Providing detailed tax-structuring advice to a large UK windfarm group. Including advice on the Substantial Shareholding Exemption (which exempts capital gains on certain disposals of a subsidiary company from UK corporation tax), and tax-planning advice relating to the potential disposal of several parts of its business by way of asset sales and share sales. Also successfully obtaining a written ruling from HM Revenue & Customs supporting our tax analysis.
- Advising a leading renewable energy business on the tax aspects of a significant windfarm development in Scotland. The wide variety of tax issues included stamp duty land tax, VA, corporation tax, and the implications of forming a Limited Liability Partnership between our client and the landowner.
- Providing corporate tax advice to a leading renewable energy client in relation to the corporate tax aspects of an acquisition of a windfarm special purpose vehicle, which was negotiated during the period in which the Government announced the end of subsidies for onshore wind projects. The lead adviser on the corporate tax aspects of the transaction, we negotiated the tax indemnity and tax warranties, and advised on stamp duty.
- Advised a renewable energy client on non-domestic rates for landfill gas projects in Scotland.
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