One minute with Tracey Wright, partner at Osborne Clarke.
You’ve just made partner at Osborne Clarke. Looking back on your career to date, what key lesson have your learned?
For me, it’s that clients find tax a challenging subject and understandably so. They rely on advisers to cut through all the complexity and to advise in a commercial way. They need advisers who are prepared to give confident and informed views. That is where experience comes into its own. It takes years to master our tax rules and to gain the intuition that you need when something doesn’t feel right and you know you need to go off and hunt for the missing bit of the legislative jigsaw. But to be successful as an adviser, you then need to be able to apply that knowledge in the commercial setting. It is really important to learn about how clients do business and where the tax advice you give fits in the bigger picture, so that you concentrate on the relevant issues.
Aside from your immediate colleagues, who in tax do you most admire and why?
It is hard to identify one person who I admire the most. I’m quite a fan of Martin Scammell. I find his practitioner text, VAT on Construction, Land and Property, extremely useful and well written. He is also an engaging speaker at conferences.
If you could make one change to UK tax law, what would it be?
Have standard definitions across all taxes to enable the law to be more easily and consistently applied. For example, in the world of property tax, what is classified as a dwelling has evolved differently for SDLT, VAT and capital allowances.
You head your firm’s tax offering in the real estate and infrastructure sector. How is the practice evolving?
It clearly follows the trends of client activity. We are seeing investment clients entering new asset classes and being prepared to consider new ways of structuring property investments. One example is institutional investment into the private rented sector, where blocks of flats are constructed for private residential rental. From a tax perspective, it is exciting because we are involved in the structuring from day one and play a part in shaping how these deals piece together.
I also advise a lot of clients who invest in or develop student accommodation. This sector has been impacted a lot by recent changes; for example, the application of the new CGT rules for non-residents holding residential property, and the VAT classification of student accommodation as a dwelling.
What caught your eye in the latest Finance Act?
Outside of the real estate sector, I also support Osborne Clarke’s recruitment sector team. I’ll be closely watching the impact of the anti-avoidance rule in the new Part 4 Chapter 7A of ITEPA 2003, which was a last minute insertion into the Finance Act. This chapter exempts expenses which are otherwise deductible for tax purposes. The changes tie into the removal of dispensations from April 2016. The anti-avoidance rule prevents expenses from being automatically exempt if (i) without the expenses, the employee would have received more by way of salary; and (ii) the motivation behind paying the expenses is the avoidance of income tax or national insurance contributions. This change has particular relevance to structures used by so called umbrella companies and links to the wider debate on how travel and subsistence expenses are paid and taxed in the recruitment sector, where further legislation is expected to be consulted on later this year.
One minute with Tracey Wright, partner at Osborne Clarke.
You’ve just made partner at Osborne Clarke. Looking back on your career to date, what key lesson have your learned?
For me, it’s that clients find tax a challenging subject and understandably so. They rely on advisers to cut through all the complexity and to advise in a commercial way. They need advisers who are prepared to give confident and informed views. That is where experience comes into its own. It takes years to master our tax rules and to gain the intuition that you need when something doesn’t feel right and you know you need to go off and hunt for the missing bit of the legislative jigsaw. But to be successful as an adviser, you then need to be able to apply that knowledge in the commercial setting. It is really important to learn about how clients do business and where the tax advice you give fits in the bigger picture, so that you concentrate on the relevant issues.
Aside from your immediate colleagues, who in tax do you most admire and why?
It is hard to identify one person who I admire the most. I’m quite a fan of Martin Scammell. I find his practitioner text, VAT on Construction, Land and Property, extremely useful and well written. He is also an engaging speaker at conferences.
If you could make one change to UK tax law, what would it be?
Have standard definitions across all taxes to enable the law to be more easily and consistently applied. For example, in the world of property tax, what is classified as a dwelling has evolved differently for SDLT, VAT and capital allowances.
You head your firm’s tax offering in the real estate and infrastructure sector. How is the practice evolving?
It clearly follows the trends of client activity. We are seeing investment clients entering new asset classes and being prepared to consider new ways of structuring property investments. One example is institutional investment into the private rented sector, where blocks of flats are constructed for private residential rental. From a tax perspective, it is exciting because we are involved in the structuring from day one and play a part in shaping how these deals piece together.
I also advise a lot of clients who invest in or develop student accommodation. This sector has been impacted a lot by recent changes; for example, the application of the new CGT rules for non-residents holding residential property, and the VAT classification of student accommodation as a dwelling.
What caught your eye in the latest Finance Act?
Outside of the real estate sector, I also support Osborne Clarke’s recruitment sector team. I’ll be closely watching the impact of the anti-avoidance rule in the new Part 4 Chapter 7A of ITEPA 2003, which was a last minute insertion into the Finance Act. This chapter exempts expenses which are otherwise deductible for tax purposes. The changes tie into the removal of dispensations from April 2016. The anti-avoidance rule prevents expenses from being automatically exempt if (i) without the expenses, the employee would have received more by way of salary; and (ii) the motivation behind paying the expenses is the avoidance of income tax or national insurance contributions. This change has particular relevance to structures used by so called umbrella companies and links to the wider debate on how travel and subsistence expenses are paid and taxed in the recruitment sector, where further legislation is expected to be consulted on later this year.
