Expertise
Tammi advises on a broad range of tax issues and is a Chartered Tax Adviser.
She regularly advises national house builder clients on the SDLT and VAT implications of land acquisition structures including tranche completions, options, promotion agreements and collaborations. Tammi is often involved in drafting applications for SDLT relief and advising on SDLT deferrals. Tammi frequently advises on residential SDLT including the evolving case law categorisation of land as residential or non-residential and the recently amended rules on the higher rates of SDLT. Recent property experience also includes advising on areas such as the disapplication of the option to tax and the tax treatment of biodiversity credits.
Tammi’s practice also includes VAT and capital allowances advice on the implications of business and asset transfers, primarily in the context of transfers of going concerns and the capital goods scheme.
She provides advice on employee share incentive schemes and advises clients on the design and implementation of enterprise management incentive schemes. She also advises on taxes in the context of employment and settlement agreements including advising overseas entities of the UK tax implications of employing UK located individuals and the UK tax implications of UK entities employing overseas individuals.
Tammi acts for corporate, individual and investor clients in the drafting and negotiation of tax provisions in share purchase agreements and business purchase agreements including where warranty and indemnity insurance is obtained and where the company is a property SPV. She also provides ongoing tax advice throughout the process of the corporate transaction and advises on corporate reorganisations and pre-sale tax planning.
Experience
- Acting for a consortium of housebuilders on the SDLT and VAT consequences of multi-housebuilder promotion and option agreements.
- Advising a private equity investor on the tax structuring of their investment into a corporate group.
- Advising on the tax implications of operating a property letting business as an unincorporated business or as a company.
- Advising a developer on the recoverability of input VAT on the sale of newly developed residential property to a housing association and advising on the structuring of the transaction so as to maximise the after-tax return.
- Advising sellers on the tax implications of a pre-sale reorganisation of a corporate group and an ultimate sale to a third party.