Linda Adelson’s experience includes:
- Advising a major investment bank on the availability of the VAT exemption for intermediary services and other related issues, in a series of twelve different complex business scenarios, including obtaining and consolidating advice from a number of jurisdictions across the EU. Writing a detailed report on the relevant legal principles underlying the advice and the possible future direction of the law.
- Successfully acting for a large insurance outsourcing supplier in a business-critical dispute with HMRC re whether their services were a single exempt supply, or included a separate taxable supply on which VAT was due. The issues were complex eg overlapping, contradictory agreements and the interaction of related intra-group arrangements with anti-avoidance rules.
- Advising a leading property fund manager on options for the VAT-efficient structuring of a new residential property investment fund.
- Advising an investment bank in relation to the VAT liability of complex services being provided in relation to specialist derivatives products and amended contracts to reflect the VAT analysis and to maximise the chances of exemption.
- Advising a large outsourcing company on the VAT treatment of cross-border recharges from its parent company, leading to a sizeable VAT saving.
- Advising on the VAT aspects of several securitisations, including the securitisation of financial receivables.
- Acting for a high street banking group in advising on the VAT aspects of a structured divestment of a portfolio of UK commercial real estate loans, using securitisation techniques in a slightly different context.
- Advising an LPA receiver on the VAT treatment of arrangements for the provision of receivership services, and their interaction with complex insolvency rules.
- Advising a large property company as to the availability of transfer of a going concern VAT relief for a complex proposed transaction and securing its substantial SDLT saving as a result.