020 3587 7800

Julian Hickey's experience includes:


Corporate M&A/Reconstructions/Private Equity/IP/Commercial/International

  • corporate transactions, including takeovers, joint ventures, demergers and corporate restructuring
  • tax planning in the case of refinancing and insolvency; including corporate support on transactions
  • various schemes of reconstruction, s.135/136 reconstructions, associated companies relief, demergers, s.110 liquidations
  • tax solutions for acquisition of equity stakes in non-UK companies and limited partnership structures
  • legal arrangements to reflect transfer pricing analysis for group transactions involving IP licensing, contract research, intra-group services
  • IP licensing/supply chain optimisation issues
  • permanent establishment issues on transactions, whether created in UK, e.g. construction sites, application of UK tax treaties, dependent agent issues, use of different types of agency arrangements, investment management exemption, attribution of profits to permanent establishment
  • establishing operations in the UK either as subsidiary or branch operations/incorporation of branches
  • Patent Box and other tax incentives for intangibles/R&D
  • royalties structures, application of EU Royalty Directive/tax treaties
  • setting up internet supply chain, and tax issues arising on a cross-border basis

 

Tax based structuring (covering a range of work: funds/real estate/debt /aircraft /IP)

  • tax aspects of property fund structuring for several leading institutions (including via onshore and offshore holding structures (direct and indirect holdings): companies, limited partnerships, and offshore trusts)
  • SDLT schemes, application of s 75A SDLT anti-avoidance, various exemptions, sub-sale schemes, application of disclosure rules, SDLT consequences of restructuring transactions
  • advised on whether a non-resident was carrying on a trade in the UK in respect of a fund
  • real estate sale and leasebacks
 

Family Office/HNWI

  • de-enveloping residential dwellings with offshore company/umbrella trust structure
  • offshore management and control issues relating to companies and trusts
  • structuring investments, and repatriation of profits from non-UK countries
 

Tax dispute resolution

  • VAT disputes involving a range of matters, including classification of supplies
  • HMRC enquiries relating to tax based structuring
  • commercial tax related disputes (including tax professional negligence)
  • advised several film partnerships on a tax dispute (£100 million tax is in issue) before the First Tier Tribunal
  • acted as Solicitor-Advocate in the Court of Appeal in a case involving a material point of legal principle. See HMRC v Banerjee [2010] EWCA Civ 843 (Court of Appeal) and the High Court hearing [2009] EWHC 62 (Ch), [2009] 1 WLR 800
  • judicial review matter (exercise of statutory discretion)
 

VAT

  • advised on the European VAT implications of a $350million restructuring of a securitisation structure
  • outsourcing arrangements
  • securitization transactions, including formation and unwinding
  • real estate structuring (including developments, student accommodation)
  • ship and aircraft leasing arrangements, application of zero-rating, importation and export
  • VAT and face value vouchers for an e-commerce provider
  • VAT and e-commerce structuring for a range of suppliers
  • place of supply issues for cross-border transactions
  • advised on imposition of penalties
  • scope of financial services exemption
  • place of supply rules and application to intermediary services