Overseas Chambers of Peter Harris

Maison de la Boucterie
Rue de la Boucterie
Saint Saviour
Jersey, JE2 7ZW

Who we are

Current instructions and what out practice includes:

Peter Harris> Peter Harris

Recent instructions have included:

Advising a City based investment /venture capital fund structuring group on the opportunities for their French resident investors to apply French capital gains relief on their start-up investments and reinvestments in the LLP and LP structures offered by the group (article 150-0 B CGI);

Advising same group on the advantageous use of look-through structures under the UK-France Income Tax Treaty;

Advising on the concepts of domicile and post 2017 deemed domicile in cross boder inheritance and capital gains tax matters . Tax Treaty taxation with credit (not exemption) over disposals of French land;

Advising a new French client who received a "nudge letter" from HMRC on how to respond;

Advising on Cayman Island and English Fund structures for French residents post-Brexit;

Advising on a complex international succession between France, Sweden and the United Kingdom and correcting French CRIDON's incorrect advice on the content of English law and the scope of and limitations on the law of adoption, its applicability outside the English jurisdiction.

 

The Practice also includes

English domestic and international Revenue and Chancery Bar practice;

The tax treatment of Trusts in France and THe UK taxtaion of French usufruits and other continental usufructs in the UK.

Please note that no further press releases or other sources of information will be released and that Peter now only advises on paid instructions.

Private and public international law; particularly the limitations on competence of national institutions within a supranational area such as the EU; and their subjecting to institutional intervention. OECD competence analysis.

BREXIT,  EU law, EU Regulations Brussels I-IV.  EU taxation issues for corporate and private individuals, advising on the removal of fiscal obstacles to freedom of movement of capital, pre- and post Brexit.

Fiscally correct offshore and onshore Tax Planning.

The private international aspects of French law involving the recognition of trusts and other foreign legal concepts, the use of civil law structures for non residents and foreigners taking up residence in France, the use of French matrimonial property régimes in France, in the United Kingdom and British Islands;

French tax law and estate planning; EU Succession Regulation N° 650/2012; the Impact of the recent French prélèvement successoral on all forms of international successioo leaving assets in France.

Multi-jurisdictional tax advice for undertakings and corporates in an international environment: BEPS and transnational working capital protection  whether in a consolidated or non-consolidated accounting or fiscal environment.

European Union law, and tax law;

European Convention on Human Rights ("ECHR") and tax implications of the right to non expropriation;

Negotiation with French and British revenue authorities;

Jersey law and income tax legislation;

Tax Treaty and Tax Information Exchange Agreement planning;

Qualified Mediator, Revenue Bar Association, Overseas Member of Chancery Bar Association; and

Tax treatment of French assurances vie à cause de vie or à cause de décès in United Kingdom.

Stamp Duty Land Tax: interests in foreign property for First Time Buyer's Relief and Apparent Ownership.

Peter is a recognised authority on countering the abusive and incorrect taxation of French usufruits by HMRC in the United Kingdom: for one example of several successes, see #HumphriesKirk, Solicitor's website.

Peter Harris is the sole person qualified to give legal and tax advice and settle opinions and advice emanating from Overseas Chambers. See the News and Press and Ressources pages for examples of areas of his expertise.

Overseas Chambers houses the overseas specialist tax and legal practice of Peter Harris, English Barrister and French tax expert. The opinions in the News & Press and Resources pages are intended for general information purposes only and should not be used as a substitute for professional advice.