We can work on a two tier system:

i) guidance of a non-advisory nature (for potential lay clients); (and then/or)

ii) full regulated legal advice for lay clients and professionals.

Recent instructions have included:

Advising a Guernsey resident parent on the gift of the nue-propriété of their Guernsey situs property holdings to a French resident daughter on a tax exempt basis before her reaching the 6/10 prior tax years of French residence, whilst retaining the usufruit and jouissance (or as they say in Guernsey "if it has to be anglicised - legal enjoyment"). It is also possible for Jersey parents with children moving to France. Why force your French resident child to pay French succession duty on a receipts basis under article 750 ter CGI on Channel Island property, you may well ask?

Advising a British widow resident in Andorra on a complex question of succession to parts in a French SCI and, working with a French notaire and Andoran advocate succeeding in having the law of the Principality of Andorra applied to the succession, thereby ensuring the application of the deceased's British law of nationality to the French transfer, excluding French forced heirship rules and employing the widow's financial rights under English partial intestacy rules to cancel the parts.

Advising English trustees on French compliance defaults -of which they were unaware- and filing a request for clemency on penalties and accompanying déclaration rectificatives for the years concerned with the French tax administration.

Advising trustees of a pre-2011 English Nil Rate Band double trust arrangement on the French compliance issues, penalties  and risks arising for a French Trustee & beneficiary after the introduction of HMRC's Register of Trusts and access to it by the French tax administration;

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 by reference to domicile, and 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 taxation 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.

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