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Taxation

At Three Stone we recognise that the context, in which tax advice must be given today, has changed over the last decade. Traditional taxes, new direct and indirect taxes, and European rules and impositions are now underpinned by an increasingly policy-driven approach and sometimes aggressive practice by H.M. Revenue & Customs. This may be supported by bold statutory interpretation and (sometimes) opaque international treaty obligations for the provision of private information.

This can bring a burdensome complication and difficulty to the modern taxpayer’s private and commercial life, whether a company, trustee or an individual. In turn, the taxpayer obviously requires highly skilled and competent legal advice.

With innovative thinking, good judgment and technical expertise we provide that and try to resolve problems and provide practical solutions.

If litigation must be then we undertake representation of the taxpayer in every pertinent tribunal and Court, from the lowest to the highest, here and overseas.

Our skills, and experience, cover the full range direct and indirect tax -both personal and corporate; this includes income tax, corporation tax and capital gains tax. As well as VAT (both domestic and European issues), customs and excise duties, stamp duties, development land tax; inheritance and business tax reliefs; issues of residence and domicile.

In terms of corporate tax, we cover company mergers, acquisitions, demergers and group reconstructions; the current judicial approach to commercial accounting, computation of profits and proper deductions against receipts; transfer pricing, double tax treaty problems and European Union cross border tax issues; the application of HMRC practices and concessions and prospects for successful judicial review if such are not implemented.

We have skill and experience in advising on “back duty”; negligence by tax professionals and judicial review of unfair actions by HMRC. We also undertake tax litigation in foreign common law jurisdictions and at the European Court of Justice.

In each sphere of taxation, we try to dovetail our advice and expertise with other Chambers’ specialities such as trusts, pensions, insolvency and commercial litigation. In respect of both domestic and offshore trusts, whether private or commercial, we have a specialist expertise in tax. This has developed over many years as a natural adjunct to advice on the creation and development of trusts situated in the United Kingdom and overseas. It is often only with a true understanding of trust law that the tax consequences of a particular transaction or course of action can be understood or anticipated.

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