In This Issue - Pinsent Masons

Issue 17 Wednesday 30 January 2013
Combining the experience, resources and international reach
of McGrigors and Pinsent Masons
PM-Tax
News and Views from the Pinsent Masons Tax team
In This Issue
Our Comment
2
Recent Articles
5
Our perspective on recent cases
6
•The GAAR commencement rules by Heather Self
•SDLT and transfers of rights by John Christian
•Long live the CSOP! by Matthew Findley
•The money-go-round: the relevance of Spargo’s
case (1873) to 21st century tax law by Conor Brindley
Procedure
•R (on the application of Prudential plc and another) (Appellants)
v Special Commissioner of Income Tax and another (Respondents)
[2013] UKSC 1
•The Secretary of State for Business, Innovation & Skills (Claimant)
v Mr Nadhan Singh Potiwal (Defendant) [2012] EWHC 3723 (Ch)
•James Edoh v HMRC [2013] UKFTT 787 (TC)
Substance
•South African Tourist Board v HMRC [2013] UKFTT 780
•BGŻ Leasing sp. z o.o. v Dyrektor Izby Skarbowej w Warszawie C-224/11
•H S Tank & Sons Limited v HMRC [2013] UKFTT 005
Events
People
Editor: Cathya Djanogly
10
11
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Our Comment
Pinsent Masons
The GAAR commencement rules
By Heather Self
First published in Tax Journal on 18 January 2013
Heather Self is a Partner
with over 25 years of
experience in tax. She
has been a partner in
Ernst & Young and Group
Tax Director at Scottish
Power, where she advised
on numerous corporate
transactions, including
the $5bn disposal of
the regulated US energy
business.
Email: heather.self@
pinsentmasons.com
Tel: +44 (0)161 662 8066
T
he commencement rules
for the GAAR have now
been announced, and are
less draconian than many had
expected.
They are set out in clause 10 of
the draft rule, with guidance in
Chapter 6 of Part A. The GAAR
will apply to any arrangements
entered into after Royal Assent,
and does not apply to any
arrangements entered into
before that date.
The rules for arrangements which
straddle the commencement
date are interesting. If the
post-commencement steps are
themselves abusive, the GAAR
will apply, but only to any postcommencement tax advantage.
If the post-commencement
steps are not abusive in their
own right, but are part of a
broader abusive arrangement,
HMRC cannot take this into
account – the earlier steps will
not ‘taint’ the later ones. But,
in contrast, the taxpayer can
take into account the overall
arrangements in order to show
that the postcommencement
steps are not abusive. The
examples in Chapter 6 of the
draft guidance are helpful in
illustrating the approach.
.
of legislation against one such
scheme on 21 December, barely
two weeks after the Autumn
Statement, shows that this risk is
high.
“
The GAAR
will apply to
any arrangements
entered into after
Royal Assent, and
does not apply to any
arrangements entered
into before that date.
Historic planning is therefore
safe from the GAAR (but may
of course be attacked under
existing rules). Those who think
that they can continue to sell
aggressive planning ideas right
up to the commencement date,
in a ‘buy now while stocks last’
campaign, may see a glimmer
of hope in the transitional
rules, but run the risk that the
government will introduce
specific blocking legislation at
short notice. The announcement
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PM-Tax | Issue 17 Wednesday 30 January 2013
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Our Comment
Pinsent Masons
SDLT and transfers of rights
By John Christian
“
First published in Tax Journal on 18 January 2013
John Christian is a partner
and head of our Corporate
Tax Team. He specialises
in corporate and business
tax, and advises on the
tax aspects of UK and
international mergers
and acquisitions, joint
ventures and partnering
arrangements, private
equity transactions, treasury
and funding issues, property
taxation, transactions under
the Private Finance Initiative
and VAT.
Email: john.christian@
pinsentmasons.com
Tel: +44(0) 113 368 7924
D
evelopers and others
using sub-sales and
similar structures
should review the proposed
changes to relief from SDLT
on transfers of rights to check
they do not affect current or
proposed structures.
The transfers of rights relief in
FA 2003 s 45 is often relevant in
development and joint venture
structures where sub-sales or
similar transactions are involved.
The draft clauses substantially
re-write the rules and the detail
will need to be worked through on
proposed transactions. The broad
effect of the s 45 relief remains,
so that an intermediate purchaser
under a sub-sale or contract
resulting from an assignment of
rights is generally relieved from
SDLT, though the relief now has to
be claimed.
Specific changes have however
been made to counter avoidance:
• a widely drawn provision
denies transfer of rights
relief where one of the main
purposes of the intermediate
purchaser is to obtain a
‘tax advantage’ from the
arrangements. It is not clear
whether ‘tax advantage’ may
relate to any tax, rather than
just SDLT. The definition of
‘tax’ in FA 2003 s 121 means
SDLT except where the
context requires. The recent
debate between HMRC
and the industry on the
availability of group relief
on hive-ups from acquired
SPVs illustrates the difficulty
that can arise in identifying
what may be regarded as
avoidance.
• a minimum consideration
is imposed on transactions
where the parties are
connected, e.g. in some
joint venture or partnering
structures, or are not acting
or arm’s length terms.
These rules may lead to
issues where the sub-sale or
assignment is completed at a
lower price than the original
contract, perhaps to reflect
movement in market values
or for other commercial
reasons.
.
The transfers
of rights relief
in FA 2003 s 45 is
often relevant in
development and joint
venture structures
where sub-sales or
similar transactions
are involved.
3
PM-Tax | Issue 17 Wednesday 30 January 2013
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Our Comment
Pinsent Masons
Long live the CSOP!
By Matthew Findley
“
First published in Tax Journal on 18 January 2013
Matthew Findley is a
partner and he advises
companies in relation to
the design, implementation
and operation of share plans
and employee incentive
arrangements both in the
UK and internationally. His
experience extends to both
executive plans (including
tax-driven structures) and
all-employee arrangements.
Matthew also has
considerable experience of
the corporate governance
and investor relations
issues associated with
executive incentives and
remuneration planning
generally.
Email: matthew.findley@
pinsentmasons.com
Tel: +44 (0)20 7490 6554
T
he government’s decision
to retain the company
share option plan (CSOP)
has been universally welcomed.
Proposed relaxations to the
CSOP legislation could, once
enacted, lead to increased
take up amongst unlisted
companies.
Significant concerns emerged
during 2012 that the CSOP was
to be scrapped as a result of
the Office of Tax Simplification
(OTS) review of HMRC approved
employee share plans.
The future of the CSOP is,
however, now much brighter.
Not only has the government
decided to retain the CSOP but it
is also taking forward a number
of changes recommended by
the OTS which would make the
CSOP available to more unlisted
companies.
PM-Tax | Issue 17 Wednesday 30 January 2013
Unlisted companies have
historically struggled to qualify
for the CSOP as the option
shares cannot be subject to
restrictions. The proposed
abolition of that prohibition
means that unlisted companies
should consider whether they
will qualify once the changes
are made. This will be of
particular relevance to those
companies which are not able
to offer enterprise management
incentives.
Note, however, that the
proposed changes do not
provide complete flexibility. For
example, companies under the
control of another company
(e.g. many private equity
backed companies) will still not
be eligible. In addition, those
companies with more than one
class of share will still need to
carefully analyse their position
under the legislation.
If the CSOP is available,
companies should also examine
who might participate. Currently,
if an employee holds 25% or
more of a company’s shares he
cannot participate in a CSOP.
That threshold is to be raised to
30% and so some substantial
shareholders who could not
previously benefit from a CSOP
will soon be able to do so.
Unlisted
companies have
historically struggled
to qualify for the
CSOP as the option
shares cannot be
subject to restrictions.
.
The proposed changes to
the CSOP legislation can be
reviewed at www.lexisurl.com/
CSOP.
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Recent Articles
Pinsent Masons
The money-go-round: the relevance of Spargo’s
case (1873) to 21st century tax law
By Conor Brindley
First published in Taxation on 10th January 2013
Conor Brindley is a Senior
Associate who specialises in
most aspects of corporate
and employee taxation.
Conor has extensive
experience of corporate
transactions including
mergers and acquisitions,
demergers and corporate
reconstructions. He also
has considerable experience
in structured finance,
securitisation and employee
incentive arrangements.
Email: conor.brindley@
pinsentmasons.com
Tel: +44 (0)20 7490 6103
T
he case of Re Harmony and
Montague Tin and Cooper
Mining Co, Spargo’s Case
(1873) 8 Ch App 407 established
the principle that where A’s
obligation to pay a sum of
money to B is set off against B’s
obligation to pay an equal sum
of money to A, the setting-off of
one payment obligation against
another is the same as the making
of the appropriate cash payments.
The result is that neither party is
required to make a cash payment.
In his judgment, Mallish LJ stated
the principle as follows:
“Nothing is clearer than that if
parties account with each other,
and sums are stated to be due on
one side, and sums to an equal
amount due on the other side on
that account, and those accounts
settled by both parties, it is
exactly the same thing as if the
sums due on both sides had been
paid. Indeed, it is a general rule
of law, that in every case where
a transaction resolves itself with
paying money by A to B, and then
handing it back again by B to A,
PM-Tax | Issue 17 Wednesday 30 January 2013
if the parties meet together and
agree to set one demand against
the other, they need not go
through the form and ceremony of
handing the money backwards and
forwards.”
Focussing on the tax implications
Although the principle in Spargo’s
Case clearly has wider relevance
other than in respect of the tax
code, it is still often relied on when
analysing the tax consequences
of a transaction which involves
one liability being set off against
another. Its continuing relevance is
most probably best demonstrated
by the fact that it continues to be
referred to in recent tax cases – see
Investment Trust Companies (in
liquidation) v CRC [2012] STC 1150
and MJP Media Services Ltd v CRC
[2011] STC 2290.
Perhaps the most useful
consequence of the principle in
Spargo’s Case is that it can relieve
a party of the obligation to obtain
short-term financing without
altering the tax consequences. This
is because it is good authority that
cash need not be “round. tripped”
where one liability is set against
another. For example, where A
owes £100 to B and B owes £100
to A and both parties agree that
the mutual obligations may be set
off against one another, A does not
need to pay £100 to B and B does
not need to pay £100 to A in order
for the liabilities to be treated as
discharged in the same way as if
actual cash payments had been
made.
Debt for equity swaps
In the current economic
environment, this relieving of an
obligation to raise short-term
financing can be particularly useful
in the context of debt for equity
swaps, where the debt has become
distressed. The general rule where
debt is swapped for equity is that
where an unconnected debtor is
released from its obligation to
repay a loan relationship debt in
consideration of the issue of shares,
any profit recorded in the debtor’s
accounts in respect of the release
will only escape a charge to tax if
CTA 2009, s 322 applies.
However, there are many factors
which can prevent s 322 from
applying. For example, the debt
may not be accounted for on an
amortised cost basis. Where s 322
cannot apply, the debtor company
can still avoid a tax charge in
respect of the “release” if the
creditor subscribes in cash for
additional shares in the debtor and
the debtor uses the subscription
proceeds to repay the debt (in
effect swapping the debt for
equity). In such circumstances, the
principle in Spargo’s Case can be
relied upon as authority that cash
need not pass from the creditor to
the debtor and then back to the
creditor provided that the debtor
and creditor agree that the debtor’s
obligation to repay the debt is to
be set off against the creditor’s
obligation to pay the subscription
proceeds. This application of
the principle in Spargo’s Case
demonstrates that the case is as
relevant in the 21st century as it
was in the 19th.
.
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Our perspective on recent cases
Pinsent Masons
Procedure
R (on the application of Prudential plc
and another) (Appellants) v Special
Commissioner of Income Tax and
another (Respondents) [2013] UKSC 1
Legal Professional Privilege does not
extend to legal advice given by someone
other than a member of the legal
profession.
which should be recognised as giving legal
advice and as to the type of advice which
would constitute legal advice.
The Supreme Court also stressed that the
extension of LPP was a matter of public
policy which should be left to Parliament.
HMRC had issued Prudential with an
information notice requesting the company
to provide various documents. Prudential
had refused to comply, contending that the
documents contained legal advice, and as
such were protected by legal professional
privilege, even though they had been
drafted by accountants and not lawyers.
HMRC obtained authorisation from the
Special Commissioners to require Prudential
to provide the documents. Prudential
sought judicial review of the decision and
lost in the first instance and on appeal.
This was an appeal of the decision of the
Court of Appeal. Upholding the decision of
the Court of Appeal, the Supreme Court (by
a majority of five to two), found that LPP
could not be extended by the courts in the
manner suggested by the appellants. The
Supreme Court noted in particular that such
an extension of the doctrine would lead
to major uncertainty as to the professions
PM-Tax | Issue 17 Wednesday 30 January 2013
Comment by James Bullock
The restriction of legal professional
privilege to advice given by a practicing
solicitor or barrister ensures that the
advice in question is given by a person
who is both professionally qualified
and rigorously regulated. That is not
to say that other professionals giving
advice on the law are not, but in any
extension of legal professional privilege
that underlying principle needs to
be maintained. This is best done by
Parliament, following an extensive
consultation.
The Secretary of State for Business,
Innovation & Skills (Claimant) v Mr
Nadhan Singh Potiwal (Defendant)
[2012] EWHC 3723 (Ch)
The relitigation in the High Court of an
issue already decided in the Tax Tribunal
can constitute an abuse of process even
when there is no privity between the
parties.
In a previous hearing, the Tax Tribunal had
held that Mr Potiwal knew that a company,
of which he was the sole director, was
participating in the fraudulent evasion of
VAT.
In a subsequent action, the Secretary
of State for Business Innovation & skills
applied for Mr Potiwal to be disqualified as
a director for having caused his company to
participate in a fraud. Mr Potiwal denied in
an affidavit that he knew or ought to have
known that his company was participating
in VAT fraud. The Secretary of State applied
to strike out this part of the evidence on
the ground that it amounted to an abuse
of process – as the issue of Mr Potiwal’s
knowledge had already been decided in the
Tax Tribunal.
determinations made in legal proceedings.
The court found that there was privity
of interest between Mr Potiwal and his
company but not between HMRC and the
Secretary of State. Although they are both
government departments with “substantial
overlap of interest”, this was not sufficient
to make them privies. However, the absence
of privity did not prevent the relitigation of
the issue of Mr Potiwal’s knowledge from
constituting an abuse in circumstances
where HMRC had already incurred
substantial costs in the proceedings and the
Secretary of State was likely to incur further
costs.
The High Court added that to find otherwise
would bring “the administration of justice
into disrepute”.
The relevant passages of Mr Potiwal’s
affidavit were therefore struck out as an
abuse of process.
Under the doctrine of res judicata, parties to
litigation and their privies are bound by any
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Our perspective on recent cases
Pinsent Masons
Procedure
James Edoh v HMRC [2013] UKFTT
787 (TC)
In the absence of strong evidence of
an agreement between HRMC and an
unrepresented taxpayer who denies the
existence of such an agreement, the
tribunal will hold that such an agreement
does not exist.
Mr Edoh appealed against HMRC’s decision
to deny a claim for £19,400 worth of
expenses representing payments made to
subcontractors for work on his business IT
equipment.
Tribunal did not have jurisdiction to reopen the appeal as it had been determined
by agreement in accordance with Section
54 Taxes Management Act 1970.
Having reviewed the evidence, the Tribunal
held that the £19,400 should have been
allowed as expenses.
The Tribunal also noted that it would
not be fair to allow Mr Edoh – who was
unrepresented - to pay far more tax than
was due as a result of a “misunderstanding,
his confusion or pressure from HMRC”.
.
The appeal was allowed.
Despite various exchanges of
correspondence and several meetings with
HMRC, what had been agreed was unclear
to both sides. This was partly the result
of HMRC mislaying Mr Edoh’s original tax
return, Mr Edoh’s accountant completing
the replacement tax return incorrectly and
a change of investigating officer on the
case at HMRC. HMRC alleged that Mr Edoh
had agreed their figures and then written
to confirm the matter as settled. Mr Edoh
submitted that he only confirmed the
matter as settled in the belief that HMRC
had accepted his position with regards to
the £19,400. HMRC submitted that the
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PM-Tax | Issue 17 Wednesday 30 January 2013
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Our perspective on recent cases
Pinsent Masons
Substance
South African Tourist Board v HMRC [2013]
UKFTT 780
The receipt by a statutory body of funds from a
government in order to carry out its statutory
duties does not constitute an economic activity for
VAT purposes.
The South African Tourist Board (“SATB”) appealed
against a decision by HMRC that it could not recover
VAT incurred on supplies made to it because it did not
carry out business activities.
The SATB was a statutory body with a statutory
duty to promote tourism in South Africa. It received
income from the South African Government (and
other entities) to be used in carrying out its duty.
The FTT accepted that the undertaking of the SATB
was serious and “earnestly pursued” in a “commercial
and efficient manner” on “sound and recognised
business principles”.
The FTT, having considered the relevant case law
extensively, also noted that “it is not necessary for the
supplier to have a motive profit in order for the supply
to be economic. But the activity must be analogous
to one that could be done for a profit.” This was not
the case for the SATB.
When the SATB received funds from the South African
Government, it was under a duty to use them for
the purpose for which it was established, and it was
obliged to refund the Government with any unused
PM-Tax | Issue 17 Wednesday 30 January 2013
funds. It was impossible for the SATB to make a profit
at the expense of the Government.
The FTT emphasised the significant distinction
between the circumstances of this appeal and the
South African Government outsourcing the functions
of the SATB to an independent third party who was
free to make a profit or carry out other activities.
The Tribunal concluded that the receipt of funds by
a statutory body (the SATB) from a government (the
South African Government) to carry out the statutory
duties for which it was established (promote tourism)
cannot be an economic activity. Therefore, the SATB
could no be carrying on a business activity for VAT
purposes.
The FTT added that “the SATB did not act as a taxable
person when receiving the government funding as
its contract with the government read “more like a
trust”. SATB was therefore not making a supply for
consideration to the government and there was no
“direct link” between the price and the services.
The position was different in relation to incidental
activities such as the sale of know-how by the SATB
and joint marketing initiatives for which the SATB
received consideration directly linked to a services
provided.
BGŻ Leasing sp. z o.o. v Dyrektor Izby
Skarbowej w Warszawie C-224/11
• The supply of leasing services together with the
supply of insurance services covering the leased
items does not constitute a single composite
supply for VAT purposes.
• The supply of insurance services by an
intermediary who is not the insurer but simply
re-invoices insurance supplies made to him
is exempt from VAT as a supply of insurance
services.
BGZ leased items to its clients and required the
insurance of these items. Clients were free to purchase
insurance from BGZ (which would provide insurance
by subscribing to the corresponding insurance with an
insurer and re-invoicing the cost of that insurance) or
to subscribe for insurance directly with an insurer.
The CJ-EU had to decide whether:
(1) the supplies of leasing services and of insurance
formed a single composite supply; and
(2) the re-invoicing of insurance services fell within
the scope of the VAT exemption applicable to
insurance services.
(1) The court noted that there is a link between
the two supplies as insurance is only of use with
respect to the item leased. However, the court also
recognised that “any insurance transaction has, by
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8
Our perspective on recent cases
Pinsent Masons
Substance
nature, a link with the items it covers.”
The court reiterated the well established case law
principle that a “service is regarded as ancillary to
a principal service in particular where it does not
constitute for the customers an aim in itself, but
a means of better enjoying the principal service
supplied.” The CJ-EU found that the insurance service
constituted an end in itself for the lessee. The position
was not changed by the fact that insurance was
compulsory as the lessee was free to subscribe for
insurance directly with an insurer. The same applied
to the invoicing and pricing arrangements which were
indicative of a single supply but not determinative in
this case.
The supply of insurance services was therefore a
distinct and independent supply.
(2) As for the re-invoicing of insurance services, the
court noted that “the essentials of an insurance
contract are, as generally understood, that the insurer
undertakes, in return for prior payment of a premium,
to provide the insured, in the event of materialisation
of the risk covered, with the service agreed when the
contract was concluded.” The court added that the
expression “insurance transactions” is broad enough
to cover the provision of insurance cover by a taxable
person who is not himself an insurer. The court also
pointed out that the principal of fiscal neutrality
precludes treating similar services differently.
The CJ-EU concluded that the provision of insurance
services by way of re-invoicing falls within the VAT
exemption for insurance.
H S Tank & Sons Limited v HMRC [2013] UKFTT
005
The uncommercial nature of a transaction coupled
with the known connection of a company director
with an earlier VAT fraud is likely to lead a tribunal
to conclude that the company knew it was entering
into a transaction connected with MTIC fraud.
H S Tank appealed a decision of HMRC to deny
the right to deduct input VAT on the purchase of
17,500 iPods on the ground that the transaction was
connected with MTIC fraud.
H S Tank’s core business was the manufacture of
garments but they had diversified into other areas
such as electronics.
In July 2006 H S Tank contracted with Fairford
Partnership Limited (Fairford) to purchase the iPod
Nanos – the price included VAT. A zero rated onward
sale to a Spanish company (UMTS) was then agreed.
The transaction formed part of a scheme intended to
defraud HMRC, although there was no evidence that
H S Tank was aware of the other traders.
The Tribunal, applying the Kittell test had to decide
whether HS Tank knew or should have known that, by
their purchase, they were participating in a
transaction connected with the fraudulent evasion of
VAT.
Having reviewed the way HS Tank had dealt with
the purchases, the Tribunal concluded that HS Tank’s
approach was not that of a reasonable business and
that its directors must have been aware of the fraud.
The Tribunal noted in particular that:
• there was no evidence of negotiations on price
between H S Tank and UMTS;
• only a single quote had been obtained from
insurance companies;
• no checks of the iPod Nanos had been carried out
by HS Tank prior to the purchase;
• Fairford and UMTS shared the same bank as H S
Tank; and
• one of H S Tank’s directors had been connected
with VAT fraud in an earlier transaction.
.
In the alternative, the Tribunal also found that if H S
Tank did not know about the connection with fraud,
the circumstances were such that they must have
realised that the only explanation for the transaction
was fraud.
9
PM-Tax | Issue 17 Wednesday 30 January 2013
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Events
Pinsent Masons
Forthcoming Seminar
The Pinsent Masons Tax team will be hosting the seminar detailed below.
To find out more or book a place, please contact Alistair McVan on 020 70542735 or [email protected]
Employment Tax Planning – Disguised Remuneration
The ‘Disguised Remuneration Rules’, introduced by the Finance Bill 2011,
received widespread criticism for being too complex, and for leaving
employers open to potential uncertainty. Over a year after the Rules were
introduced, Matthew Rowbotham of Pinsent Masons Tax, takes stock.
He discusses how the Rules work, their effect on share plans and EFRBS
planning, as well as the wider implications of this type of legislation for
businesses.
Matthew will be joined by Matthew Findley, partner in our specialist
Share Plans team. There will be ample time for questions at this event.
Date: Tuesday 5th February
Venue: Pinsent Masons, 30 Crown Place, London EC2A 4ES
10
PM-Tax | Issue 17 Wednesday 30 January 2013
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People
People
Pinsent Masons
Tax Planning – Is there life after the GAAR?
T
he tax team hosted an evening seminar on 24 January to
discuss the General Anti Abuse Rule (GAAR), which was well
attended by tax directors and private wealth advisers. James
Bullock chaired a panel of three experts: Emma Chamberlain,
a barrister at Pump Court Tax Chambers specialising in tax and
trust advice for private clients; Judith Freedman, Professor of
Taxation Law and Director of Legal Research at Oxford University
and Heather Self of Pinsent Masons.
Each of the panellists outlined their response to the GAAR. Judith
Freedman began by explaining some of the concerns she had with
the way the draft legislation had developed from that originally
proposed by Graham Aaronson’s report. Judith had been a member
of the study group advising Graham Aaronson. She was concerned
that the advisory panel, which was only supposed to have an
advisory role, was becoming too important and she felt that it
was a mistake to have removed HMRC representatives from the
panel. Emma Chamberlain, who is to be a member of the interim
GAAR advisory panel, highlighted some of the areas where the draft
legislation did not work well for trusts and capital tax planning.
She was concerned about how self assessment would work for
capital taxes and how counteraction would work for inheritance tax
schemes that had CGT consequences. Heather Self looked at the
rules from the perspective of large corporates. She was concerned
that the draft guidance should be expanded to cover some more
good examples of arrangements that would not be caught by the
GAAR and encouraged attendees to engage with HMRC as part of
the consultation process to get as much clarity as possible on what
would be covered.
The presentation was followed by a discussion of points raised by
attendees. Most discussions surrounded the issue of whether HMRC
would deploy the GAAR before or after other legislation. A straw poll
of attendees revealed that everyone was in favour of decisions of
the advisory panel being published regularly and several delegates
queried why only annual digests would be published.
.
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of McGrigors and Pinsent Masons
Pinsent Masons LLP, a limited liability partnership registered in England & Wales (registered number: OC333653) authorised and regulated by the Solicitors Regulation Authority and the appropriate regulatory body in the other jurisdictions in which it operates. The word ‘partner’, used in relation to the LLP, refers to a member of the
LLP or an employee or consultant of the LLP or any affiliated firm of equivalent standing. A list of the members of the LLP, and of those non-members who are designated as partners, is displayed at the LLP’s registered office: 30 Crown Place, London EC2A 4ES, United Kingdom. We use ‘Pinsent Masons’ to refer to Pinsent Masons
LLP and affiliated entities that practise under the name ‘Pinsent Masons’ or a name that incorporates those words. Reference to ‘Pinsent Masons’ is to Pinsent Masons LLP and/or one or more of those affiliated entities as the context requires. © Pinsent Masons LLP 2013.
For a full list of our locations around the globe please visit our websites
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www.pinsentmasons.com | www.Out-Law.com
PM-Tax | Issue 17 Wednesday 30 January 2013
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