Patrick Ford
Patrick Ford's expertise covers advising on the tax implications of corporate finance and property transactions as well as tax structuring opportunities in connection with such transactions and corporate restructuring generally.
Patrick has varied experience of employee incentive work and has drafted documentation for, implemented and advised on the operation of a wide range of equity based employee incentive arrangements. He also has extensive experience of advising on employment and pensions tax related issues.
Patrick was ranked the top tax lawyer in the north west of England in Chambers UK 2014 and Chambers UK 2015, with comments including that "he has the pulse and understands how tax works - you think to yourself, 'he's a find'" and "he provided fantastic support on complex tax issues. He was extremely responsive to our deadlines and got to understand our ways of working very quickly.'
Representative experience:
- acting for UK and non-UK companies (quoted and unquoted) on the tax aspects of corporate and property acquisitions and disposals and the tax-efficient structuring of such transactions
- advising UK and non-UK private companies on tax-efficient group restructuring
- providing tax planning and advice for vendors of private companies
- acting for UK and non-UK companies (quoted and unquoted) on the implementation and operation of various UK and international employee share incentive schemes
- advising on various employee-related tax issues, including redundancy programmes, agency worker arrangements, bonus scheme structuring, salary sacrifice and secondments
- advising UK companies and pensions trustees on pensions tax issues and planning
4 Contributions by Patrick Ford
PRACTICE NOTES
Offshore employment intermediaries: UK PAYE/NICs liabilities post-FA 2014—agency and host-employer rules, continental shelf, travel expenses and practical considerations
Offshore employment intermediaries—income tax provisions
This Practice Note sets out the income tax rules relevant to offshore employment intermediaries. It includes an outline of the position before and after the amendments brought in by the Finance Act 2014 (FA 2014), together with practical points to consider. The offshore employment intermediaries regime applies where an offshore intermediary entity is used to arrange the provision of services by UK workers. The rules are primarily designed to ensure that employment taxes—National Insurance contributions (NICs)—are accounted for when offshore employers engage UK workers who ultimately perform work for companies based in the UK. For the treatment of onshore employment intermediaries, see Practice Notes: Onshore employment intermediaries—income tax provisions and Onshore employment intermediaries—key practical considerations...
Tax
PRACTICE NOTES
UK onshore employment intermediaries: ITEPA 2003 s44 agencies legislation—post-FA 2014 scope, SDC, deemed employer, travel expenses and anti-avoidance
Onshore employment intermediaries—income tax provisions
This Practice Note outlines the income tax rules relevant to onshore employment intermediaries. For further details of the practical considerations, refer to Practice Note: Onshore employment intermediaries—key practical considerations. These onshore employment intermediary provisions broadly apply where an onshore intermediary entity is interposed to arrange the supply of a worker’s services under the legislation. The regime is broadly designed to prevent genuine employment being artificially presented as self-employment to cut employment taxes, in particular National Insurance contributions (NICs). For the income tax framework that applies to offshore employment intermediaries, see Practice Note: Offshore employment intermediaries—income tax provisions and key practical considerations...
Tax
PRACTICE NOTES
UK onshore employment intermediaries: practical guidance on supervision, direction or control, personal services, agency chains, IR35 interaction, PAYE/RTI reporting, documentation and risk allocation
The onshore employment intermediaries legislation generally applies where an onshore intermediary is engaged to arrange the supply of a worker’s services. Its purpose is to prevent real employment being misrepresented as self-employment to cut employment taxes—especially National Insurance contributions (NICs)—and to avoid costs linked to statutory employment rights. For a fuller explanation, see Practice Note: Onshore employment intermediaries—income tax provisions. That Practice Note focuses on the practical aspects of the rules.
Onshore employment intermediaries
The consultation leading up to the 2014 launch of the onshore intermediaries rules exposed a range of issues with the definition and application of ‘supervision, direction or control’ within the amended legislation. Following that feedback, HMRC made limited revisions while the provisions were in draft and has also released guidance on the crucial phrase ‘supervision, direction or control’...
Tax
PRACTICE NOTES
UK tax deductibility and timing of Pensions Act 1995 section 75 employer debts in defined benefit occupational pension schemes: spreading, apportionment/withdrawal, investment company rules, and subsidiary disposals
This practice note concerns defined benefit occupational pension schemes.
What is a section 75 debt?
Sections 75 and 75A of the Pensions Act 1995 aim to ensure defined benefit occupational pension schemes are properly funded on wind-up, or when the sponsoring employer goes into liquidation. In a multi-employer arrangement, a liability also arises for any employer that stops employing active members while another employer still has at least one active member (an ‘employment cessation event’), even though neither the scheme nor the exiting employer is being wound up.
For further detail on when section 75 debts arise and how they are assessed, see the following Practice Notes:
How to deal with a section 75 debt—an introduction
When is a section 75 debt triggered?
Calculating a section 75 debt
What is the tax treatment of a section 75 debt?
When a section 75 debt is payable, the key tax question is whether the payer can claim a tax deduction. Put another way, is the payment an allowable expense that reduces the payer’s...
Pensions
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