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Conference Date: Thursday, 26 Nov 2026
Venue: The Oval Cricket Ground, London

Conference Programme

  • 8:30 am -  
    Registration and Coffee
  • 9:30 am - Pete Miller 
    Chair's opening address
  • 9:40 am - Nigel Holmes 
    R&D tax relief – where are we now?
    • The new “merged” scheme
    • Recent R&D tax cases
    • The compliance regime – have we turned a corner?
    • ADR and R&D – our experiences
  • 10:40 am -  
    Coffee Break
  • 11:00 am - Jonathan Schwarz & Jivaan Bennett  
    Key international tax developments
    • US LLCs and transparency
    • Reforms to the foreign PE exemption regime and WHT on interest
    • Short-term business visitors relaxation
    • OECD Model Convention – updated commentaries on PE home offices
    • Case law update
  • 12:00 pm - David Pett 
    EOTs, share options, JSOPs and SIPs – an update
    • What are ERS? – the fallout from the Vermilion decision:
    • - “founder’s shares”
    • - are “additional shares” ERS?
    • EOTs/EBTs:
    • - the 2024 and 2025 changes to EOT rules
    • - securing the interests of the vendors
    • - issues on sales of an EOT-owned company
    • - Adams v FSC – creditors vs beneficiaries
    • EMI and CSOP share options
    • - issues arising on due diligence
    • - the independence requirement
    • - early exercise and sales for cash
    • SIPs & SAYE
    • - responses to the 2023 call for evidence
    • - why are they not more widely adopted?
    • The continuing attraction of JSOPs over “growth shares”
  • 1:00 pm -  
    Lunch
  • 2:00 pm - Pete Miller & Nick Wright 
    Reorganisation anti-avoidance: the brave new world
    • What’s old: where we were and why the rules changed
    • What’s new: what the new rules do
    • What’s positive: why the new rules make more sense
    • What’s blue: practical issues.
  • 3:00 pm -  
    Coffee Break
  • 3:15 pm - Rebecca Bonner 
    Pensions and IHT planning after April 2027 – all change
    • Losing the residence nil rate band: what its removal means and how to adapt estate plans accordingly
    • Annuities revisited: why annuities may regain relevance and how they could fit into post-2027 retirement strategies
    • Income & lifetime gifts: structuring withdrawals and gifts to reduce IHT exposure while supporting family goals
    • Discretionary trusts & the frozen nil rate band: using trusts to manage rising estate values amid threshold freezes
    • Life insurance: how insurance can provide an affordable medium term solution alongside a gifting strategy
  • 4:15 pm - Sarah Squires & Philip Simpson KC 
    Latest tax cases update – a view from the bar
  • 5:15 pm - Pete Miller 
    Chair’s closing remarks and final questions
  • 5:20 pm -  
    Conference Close

DELEGATE FEES

For payments received by 24/10/2026

£675 + vat per delegate

...or book 4 places for the price of 3

For payments received after 24/10/2026

£725 + vat per delegate

...or book 4 places for the price of 3

Register online for this conference
Chairman & Speaker
Pete Miller
Jerroms Miller

Speaker Biography - Pete Miller

Pete offers expert advice to other advisers on all business and corporate tax issues. Pete’s specialist areas include corporate reconstructions and reorganisations, HMRC clearances, the transactions in securities rules, distributions, partnerships, Patent Box, disguised remuneration and the taxation of intangible assets.

Pete has worked in tax for over 33 years, including nearly 10 years as an Inspector of Taxes. He worked in Birmingham and London with roles in both Policy and Technical Divisions, where he was the Inland Revenue’s expert on all matters relating to the distributions legislation. He then worked for 11 years in ‘Big 4’ firms, specialising in the taxation of corporate transactions.

Pete speaks and writes regularly on tax issues and is General Editor of Whiteman and Sherry on Capital Gains Tax and on Income Tax and a member of the Editorial Boards of Taxation, The Tax Journal and Simon’s Taxes. He is lead author of Taxation of Company Reorganisations (6th edition, Bloomsbury Professional, October 2020), co-author of CCH’s book on Taxation of Partnerships and author of Tax Digests on Corporate Reconstructions, Transactions in Securities, Partnership Taxation, Disguised Remuneration, the Substantial Shareholding Exemption and the Patent Box and of the ICAEW Tax Faculty’s TAXGuide on the 2017 regime for carried forward corporate losses.

Visit Jerroms Miller website

Speaker Biography
Speakers
Nigel Holmes
Ryan

Speaker Biography - Nigel Holmes

Nigel Holmes FCA CTA is a Chartered Accountant and Chartered Tax Adviser and is Director, Research and Development at Ryan.

He has over 20 years experience in R&D tax relief and has lectured and written widely on the subject.

In 2017 he was shortlisted for Taxation’s Tax Writer of the Year award. He joined Ryan (formerly Catax) in April 2017 after nearly 25 years at a large regional practice.

Visit the website

Speaker Biography
Jonathan Schwarz & Jivaan Bennett
Temple Tax Chambers

Speaker Biography - Jonathan Schwarz & Jivaan Bennett

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII

Jonathan is an English Barrister at Temple Tax Chambers in London and is also a Canadian Barrister, a South African Advocate and an Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems.

He is a visiting Professor at the Dickson Poon School of Law, King’s College London where he is Programme Director of the LLM (International Tax Law).

He is the author of Schwarz on Tax Treaties 5th Ed and Booth and Schwarz: Residence, Domicile and UK Taxation 20th Ed among other publications and a contributor to Transfer Pricing and Business Restructurings: Streamlining all the way. He has been listed as a leading tax Barrister in both the Legal 500 by reference to recommendation for international corporate tax, and Chambers’ Guide to the Legal Profession by reference to international transactions and particular expertise in transfer pricing. In the Chambers Guide he is commended for his ‘encyclopaedic knowledge of double tax treaties’ and described as “clearly amongst the best international tax barristers”. In Who’s Who Legal UK Bar 2016, he is lauded for his “brilliant” handling of cross-border tax problems. In Chambers UK Bar 2018 he is “highly regarded for his expertise in international tax matters.” In the Legal 500 UK Bar 2019 he is rated as “the leading advisor on international tax treaty issues.” In Chambers UK Bar 2020 he is identified as “The double tax guru” with “extraordinary depth of knowledge and experience when it comes to tax treaty issues, and is a creative thinker and a clear and meticulous writer.”

Jivaan Bennett

Jivaan advises on all areas of UK and Caribbean tax law (contentious and non-contentious) with a particular focus on international tax law issues, tax-related corporate disputes (such as tax warranty and indemnity claims and other post-completion claims) and tax issues arising in the sports and entertainment industries. Jivaan is recognised for combining technical rigour with a strong commercial focus. He works seamlessly with those instructing him, leveraging his tax advisor and solicitor background to anticipate client needs, coordinate strategy, and deliver practical, outcome-driven advice.

He offers a rare combination of more than 15 years’ experience, gained both in the UK and internationally, advising on the tax aspects of corporate and commercial transactions, tax disputes and tax-related corporate disputes (both litigation and arbitration).

 

Speaker Biography
David Pett
Temple Tax Chambers

Speaker Biography - David Pett

David first trained as a tax lawyer at what is now Clifford Chance and has over 40 years’ experience of all aspects of direct corporate and personal UK taxes.

Having been, for many years, a senior partner and head of tax at Pinsent Masons and, after 8 years practising as the founding partner in an eponymous law firm, David transferred to the Tax Bar in 2017 and resumed his more general tax advisory practice as a member of Temple Tax Chambers.

He is author and co-editor of the 2-volume looseleaf “Employee Share Schemes”, published by Thomson Reuters, and is also author of recently-published books on “Employee-ownership Trusts” (2022) and “Disguised Remuneration & the Loan Charge”(2021) (both published by Claritax Books).

Speaker Biography
Nick Wright
Jerroms Miller

Speaker Biography - Nick Wright

Associate director Nick joined Jerroms as a Corporate Tax Manager in 2019 to undertake technical tax research, planning and advisory projects for our business and corporate clients.

Nick provides specialist corporate tax advice in areas such as transactions tax, company reconstructions and Employee Ownership Trusts, Employment Related Securities and employee share schemes both to individuals and to accountants and solicitors requiring support for their own clients.

Visit the Jerroms Miller website

Speaker Biography
Rebecca Bonner
Trigpoint Financial Planning

Speaker Biography - Rebecca Bonner

In addition to being an Independent Financial Adviser, Becky has a strong background in private client tax.

She is CTA, TEP and DipFS qualified and is the Managing Director of Trigpoint Financial Planning.

Speaker Biography
Philip Simpson KC & Sarah Squires
15 Old Square Tax Chambers

Speaker Biography - Philip Simpson KC & Sarah Squires

Philip Simpson KC

Philip is a CTA-qualified tax advocate and barrister, specialising in all areas of tax law. He is ranked for tax by both Chambers UK and the Legal 500. His areas of expertise include income tax, capital gains, stamp duties, VAT and corporate tax.

Sarah Squires

Sarah has over 20 years of experience of advising on corporate tax on a wide range of matters. Her experience includes M&A, capital markets, finance and real estate.

As well as advising clients on tax, Sarah provides support (as a consultant) to various trade bodies in the real estate sector in relation to tax policy. This has included work on the changes to the taxation of non-resident owners of UK land, REITs and the introduction of “qualifying asset holding companies”.

Sarah is also a member of the Tax Law Committee of the Law Society of England & Wales, and since 2019 has been a specialist adviser to the House of Lords Finance Bill Sub-Committee. In January 2026, she was appointed Assistant Editor of the British Tax Review.

Speaker Biography

Conference Brochure

Click to download

Full details of the speakers and topics for this conference will be posted as soon as they are finalised. Normally 4-5 weeks before the conference date.

Delegates will receive a comprehensive set of notes to take away and will have the opportunity to ask questions of any of the speakers both on the day and in advance of the conference. This conference will provide 6 hours CPD / CPE and will offer the chance to network with other local senior tax professionals.

This conference features a “4 for the price of 3” offer so that key members of your tax team can attend and hear the latest ideas first-hand.

 Please contact us with any booking queries.
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