Elevenses Tax Series

Elevenses with Devereux is our tax webinar series. Members of the Devereux tax team give an informal but informative presentation on a topic of current interest. 

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Disclaimer: These webinars contain the personal views of the barristers involved at the date of broadcast on topics of general interest. They should not be relied upon as constituting legal advice.


R (Haworth) v HMRC

On Friday 16 July, Aparna Nathan QC and Christopher Stone will discuss the Supreme Court’s judgment in R(Haworth) v HMRC including:

  • Its impact on HMRC’s ability to give follower notices
  • The scope to challenge follower notices by way of judicial review
  • The implications for those appealing follower notice penalties to the FTT

To register for this webinar, please click here

SDLT: recent developments on the meaning of ‘dwelling’

Barrie Akin and Colm Kelly present "SDLT: recent developments on the meaning of 'dwelling'". 

This webinar was broadcast on 16th April 2021. 

Tricky Treaty Points

Felicity Cullen QC and Barrie Akin discuss tricky treaty points - circumstances and cases in which the application of Double Tax Treaties has been problematic.

This webinar was broadcast on 12th February 2021.

End of Year Review & Panel Discussion

This webinar was broadcast on 18th December 2020.

The Taxation of Interest and its Sources

Barrie Akin and Christopher Stone discuss The Taxation of Interest and its Sources. 

This webinar was broadcast on 11th December 2020.

Charman v HMRC – the scope and application of the “by reason of employment” test 

Akash Nawbatt QC and Kate Balmer discuss the recent decisions of the Upper Tribunal in Charman v HMRC and Vermilion v HMRC. In particular they consider  (i) the meaning of the “by reason of employment” test; (ii) whether there is any material difference with the “from” employment emoluments test; (iii) the application of the “by reason of employment” test where there is one more than one operative cause; and (iv) the correct approach to identifying the date when share options are acquired.

This webinar was broadcast on 4th December 2020.

Fowler v HMRC: implications for the interpretation of double taxation conventions

Akash Nawbatt QC and Colm Kelly consider the recent Supreme Court decision in Fowler v HMRC, in which they appeared.

This webinar was originally broadcast on 17th July 2020. 

Partnerships and Inheritance Tax

Marika Lemos introduces some of the difficult practical issues that arise in the context of inheritance tax, when planning with existing partnerships and LLPs. Followed by a discussion with Felicity Cullen QC and Aparna Nathan QC

This webinar was originally broadcast on 10th July 2020. 

A Practical Insight into Mutual Agreement Procedures

Felicity Cullen QC and Christopher Stone consider practical aspects of Mutual Aggrement Procedures. Colm Kelly also provides an update on electronic bundles. 

This webinar was originally broadcast on 3rd July 2020. 

Transfer of Assets Abroad: key features and case update

Rebecca Murray and Sam Way decode the key features of the complex TOAA rules and explain recent developments.

This webinar was originally broadcast on 26th June 2020. 

Embiricos, LevyHenkes: To close or not to close?

Akash Nawbatt QC and Sebastian Purnell discuss the issue of closure notices in domicile enquiries in light of the recent cases of Embiricos, Levy and Henkes

This webinar was originally broadcast on 19th June 2020. 

Farming losses: when is the restriction to sideways loss relief lifted?

Marika Lemos and Felicity Cullen QC outline the restriction to sideways loss relief in s.67 ITA 2007 and the circumstances when the 5-year rule is relaxed by reference to the decisions of the Upper Tribunal in  Scambler v HMRC [2017] UKUT 1 and in Naghshineh v HMRC [2020] UKUT 0030. 

This webinar was originally broadcast on 12th June 2020. 

Judicial review as a remedy in the tax context

Timothy Brennan QC and Christopher Stone speak on judicial review as a remedy in the tax context, with a focus on legitimate expectation and conspicuous unfairness.

This webinar was broadcast on 5th June 2020.

Accounting and tax debits after NCL Investments

Jolyon Maugham QC discusses accounting and tax debits after the Court of Appeal’s judgment in NCL Investments.

This webinar was broadcast on 5th June 2020.

An Update on the FTT with Judge Sinfield

In a special edition of Elevenses with Devereux, Upper Tribunal Judge Greg Sinfield discusses the challenges which the COVID-19 pandemic is posing for the work of the FTT.

This webinar was broadcast on 22nd May 2020.

Partnerships and Enquiries

Aparna Nathan QC and Marika Lemos discuss partnerships and enquiries – including the recent UT and Court of Appeal decisions in Reid and Emblin v HMRC and R (Amrolia) v HMRC.

This webinar was broadcast on 15th May 2020.

Unallowable Purpose

Christopher Stone and Anna Greenley consider recent developments in the law and practice on "unallowable purpose".

This webinar was broadcast on 7th May 2020.

SDLT and the definition of “Residential Property”

Barrie Akin and Colm Kelly discuss SDLT and the definition of "residential property" with a focus on the meaning of “garden or grounds”.

This webinar was broadcast on 1st May 2020.

LLPs: Mixed Membership Partnership Rules and Profit Attribution

Aparna Nathan QC and Rebecca Murray talk about LLPs: Mixed Membership Partnership Rules and Profit Attribution.

COVID-19: implications for corporate residence and individual residence under the SRT

Akash Nawbatt QC considers the implications of COVID-19 for corporate residence and individual residence under the SRT. 

This webinar was broadcast on 17th April 2020.

Arron Banks v HMRC: the implications for discrimination claims in the tax context

In the first edition of Elevenses with Devereux, Christopher Stone discusses the UT’s judgment in Arron Banks v HMRC.

This webinar was broadcast on 9th April 2020.

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