Simon Howley

Managing Partner

ATT, CTA, ATA, AFA, MIPA

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The co-founder of Bell Howley Perrotton with over 25 + years of experience working within City law firms and accountancy practices.

Simon oversees the firms tax team, is a member of the Association of Taxation Technicians, Chartered Institute of Taxation, Federation of Tax Advisers, Institute of Financial Accountants and the Institute of Public Accountants (Australia).

 

Simon sits on the Property Taxes Sub Committee of the CIOT’s Technical Policy and Oversight Committee. The sub-committees are all heavily involved in consultation with Government, in public and in private, on proposed tax legislation. An important example of this is the thorough line-by-line review in limited time while the Finance Bill is before Parliament. Weaknesses and anomalies in legislation and drafting are identified and representations are made appropriately.

 

Simon is also a Freeman of The Worshipful Company of Tax Advisers in the City of London.

+44 20 7129 1432

Experience

Example of work carried out:

 

  • Advising Hong Kong purchaser in relation to purchase of residential property in the UK and the 2% non-residents SDLT charge.

  • Numerous successful applications of s77 FA 1986 clearances for exemption from Stamp Duty on company reconstructions.

 

  • Advising client on the availability of Multiple Dwellings Relief in relation to the purchase of a farm and mixed use SDLT rates.

 

  • Advising multiple clients on the Para 10 and 18 Schedule 15 FA 2003 issues on incorporation of general partnerships and LLP’s.

 

  • Correction of numerous SDLT 1 forms wrongly submitted to HMRC on behalf clients.

 

  • Claiming the 3% higher rate SDLT charge refund on behalf of a client’s replacement of main home, within the 3 year window.

 

  • Advising client on the purchase of bare arable land and a separate plot of land in an nearby building plot and linking the transaction to secure non-residential rates.

 

  • Advising and claiming Multiple Dwellings Relief in relation to an annex on a house purchase.

  

  • Advising on whether the purchase of three flats in the same building, with the intention of knocking through into one home, will be treated as a replacement of main residence for the purpose of the SDLT 3% charge.

 

  • Multiple advisory matters in relation to Multiple Dwellings Relief, and what constitutes a dwelling.

 

  • Advising on the purchase of a property from the executors of an estate, and the availability of exemption from SDLT.

 

  • Advising on a proposed transfer of property from a general partnership into a LLP, and the possibility of a double charge under Para 10 and 18 Schedule 15 FA 2003 and the interaction of Para 23 to avoid this. 

  • Advising a property group on the VAT issue of demolishing an existing building to build 9 leasehold apartments, and associated group relief claims for Stamp Duty Land Tax and Capital Gains
     

  • Advising a client with a Transfer of a Going Concern application on the purchase of a shopping centre from a well know charity
     

  • Submitting a HMRC application for Seed Enterprise Investment Scheme for a new social media F1 Motorsports platform
     

  • Securing a refund of Stamp Duty Land Tax from HMRC with Multiple Dwellings Relief
     

  • Advising a client on the correct interpretation of the anti-avoidance provisions contained within Paragraph 17A, Schedule 15 FA 2003 for Stamp Duty Land Tax
     

  • Assisting a client with a capital allowances claim on a newly acquired commercial premises
     

  • Assisting and advising on an Isle of Man Trust remuneration scheme on relation to income tax charged under Part 7A ITEPA 2003, income tax charges under s23Aff ITTOIA 2005
     

  • Advising on the Capital Gains tax issues of an Isle of Man trust acquiring shares from the controlling shareholders of UK company
     

  • Implementing an Employee Management Incentive share option scheme and negotiation of share value with HMRC Share ‘Valuations
     

  • Assisting a client valuing and agreeing a financial settlement in a partnership dispute
     

  • Creating a group structure for a property client using HMRC clearance and share for share exchange
     

  • Dealing with HMRC Capital Taxes enquiry into an inheritance tax issues and subsequent First Tier Tax Tribunal hearing
     

  • Advising on the Stamp Duty Land Tax, Capital Gains Tax issues on the incorporation of clients Limited Liability Partnership into a newly formed group and the splitting of titles various properties and creating of leases to subsidiary companies.
     

  • Advising on the possible statutory demerger of a vendors property group, in order to split assets up for sale, or retention
     

  • Defending a group of 1,800 clients against HMRC enquiry for the use of three separate Stamp Duty Land Tax anti-avoidance schemes
     

  • Advising on the implication of the use of Employee Benefit Schemes and Employee Funded Retirement Benefit Schemes in light of the Disguised Remuneration Rules
     

  • Advising on the creation of a Family Investment Company and the creation of the required share rights
     

  • Advising on the extraction of commercial property from a company into a Limited Liability Partnership in relation to Stamp Duty Land Tax and Capital Gains
     

  • Advising and dealing with HMRC Loan Charge assessments issued to client