Etienne Wong
Etienne qualified as a solicitor in 1990, and was a partner and head of the international VAT unit at Clifford Chance LLP from 1999 to 2014.
He was called to the Bar in 2014.
Etienne has been advising on all aspects of VAT since 1989, and appeared in Band 1 in Chambers Global as an "excellent choice for indirect tax matters".
In particular, he advises on the VAT treatment of:
- financing transactions (including structured finance, securitisations, asset finance, commodities transactions, factoring and Islamic financing)
- real estate transactions
- insurance transactions
- corporate acquisitions and disposals
- funds
- private equity transactions
- outsourcing transactions
- transactions in the transport sector (including transactions in aircraft, vessels, trains and automobiles)
- e-commerce and other new media transactions
- transactions in the leisure sector
- transactions in the power and energy sectors (including solar panel financing, transactions in carbon credits and renewable energy projects)
He also advises on tax matters generally — in particular, the direct and indirect taxation of:
- real estate transactions (e.g. property development, property investment)
- outsourcing transactions
- transactions in the power and energy sectors (e.g. solar panel financing, biomass projects)
- e-commerce and other new media transactions and transfer pricing, insurance premium tax and customs and excise duties.
He also advises on disputes with HMRC.
Etienne has authored several articles and spoken at various conferences both within the UK and abroad, and was the author of the tax chapter of the Outsourcing Practice Manual and the co-author of the European Union chapter of the Inward Investment and International Taxation Review.
Practice Areas
Panel
- Contributing Author
4 Contributions by Etienne Wong
![EU law and direct taxation: fundamental freedoms, compatibility tests and remedies; UK implications (CFC, group relief), preliminary references, and EEA/Swiss scope [Archived]](images/default-source/pa-pool/3.tmb-small.jpg)
PRACTICE NOTES
EU law and direct taxation: fundamental freedoms, compatibility tests and remedies; UK implications (CFC, group relief), preliminary references, and EEA/Swiss scope [Archived]
ARCHIVED:
This Practice Note has been archived and is no longer maintained. It considers the relationship between EU law and the direct tax rules of EU Member States, and, in particular, what occurs where a domestic direct tax provision appears to be incompatible with an EU fundamental freedom. The Note also describes the effect that EU law had on the UK’s direct tax regime while the UK was bound by EU obligations, ie up to the end of the Brexit implementation period on 31 December 2020 (IP completion day). Unless expressly stated otherwise, references here to judgments of the EU Court of Justice are to judgments handed down before IP completion day. For guidance on the extent to which EU law continued to influence UK direct tax rules after IP completion day and until 31 December 2023, see Practice Note: Retained EU law and tax. For an explanation of the position from 1 January 2024, see Practice Note: Assimilated law and tax. Note that the freedom of establishment, though not the right to the free movement of capital, was specifically repealed by regulations with effect from IP completion day...
Tax
PRACTICE NOTES
EU VAT general principles in the UK: fiscal neutrality, proportionality, legal certainty, legitimate expectations, equivalence and effectiveness; direct effect, conforming interpretation and post-Brexit implications
EU legal principles
For EU Member States, Council Directive 2006/112/EC (the VAT Directive) establishes the framework for a common VAT regime, which every Member State must transpose into its own legal order through domestic legislation. That national legislation must not only give proper effect to the VAT Directive, but be enacted and applied in a way that accords with a series of EU legal principles (the EU general principles). This was undoubtedly so in the UK while it remained an EU Member State. What has followed since the UK’s exit from the EU is covered in Practice Notes: Retained EU law and tax, Assimilated law and Assimilated law and tax. A summary of the key points appears at the end of this Practice Note; suffice it to say for now that EU general principles have not—contrary to some expectations or hopes—been consigned to the dustbin of UK fiscal history. This Practice Note concerns EU legal principles that commonly arose in a VAT context. It also addresses the duty on UK courts to construe UK VAT legislation, so far as possible, in conformity with the VAT Directive...
Tax
PRACTICE NOTES
UK Cryptoassets Tax: Income Tax, CGT, Corporation Tax, VAT, Stamp Duties and Employment; Situs and NFTs; FA 2025 Residence-based IHT and DeFi Lending/Staking Proposals
STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime
The Finance Act 2025 (FA 2025), granted Royal Assent on 20 March 2025, enacts the removal of the remittance basis and introduces a residence-based system from 6 April 2025. This shift takes effect from 6 April 2025, fully supplanting the prior remittance basis entirely. FA 2025 also substitutes domicile as the principal determinant of liability to inheritance tax. Additional reforms include revising the rules for excluded property status, ending the protected settlements status for offshore trusts, and updating overseas workday relief. For further information on these measures, see: Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.
FORTHCOMING CHANGE :
On 27 April 2023, the former Conservative government launched a consultation (closing 22 June 2023) on altering the tax treatment of decentralised finance (DeFi) cryptoasset lending and staking transactions. The consultation sought views on implementing a proposal to disregard, for capital gains tax purposes, disposals of beneficial ownership arising in certain cryptoasset lending and staking transactions. Instead, a charge would crystallise when the cryptoassets are economically disposed of (eg on an outright sale). The intention of...
Tax
PRACTICE NOTES
UK VAT on sukuk: characterisation as bonds, collective investment schemes or property; supplies and land rules (Schedule 10 para 40 VATA 1994)
This Practice Note
This Practice Note summarises the UK VAT position generally on the issuance of a sakk by an issuer to an investor (ie, the sakk holder) in this context. A sakk is a certificate granting the holder specified rights to receive payments periodically, from time to time. Its principal features broadly mirror those of a bond (or comparable financial instrument). ‘Sukuk’ is the plural of ‘sakk’. A sukuk issue is a type of Islamic financing arrangement. For broader guidance on Islamic finance, see Practice Note: Key principles of Islamic finance. For details on other, non-VAT, tax considerations for sukuk, see Practice Notes: Sukuk—investment bond arrangements and their UK direct tax treatment, Sukuk—investment bond arrangements and stamp duty and SDRT, and Sukuk al ijara—tax reliefs for sale and leaseback arrangements. This Practice Note proceeds on the basis that:
the issuer is a corporate special‑purpose vehicle entity
both the issuer and the sakk holder are UK‑established for VAT purposes in relation to the sukuk issuance
any trust property held by the issuer that amounts to land, or goods for VAT purposes, is located (and remains) in the UK, and
each transaction entered into by the issuer or the sakk herein...
Tax
If you expected to see yourself on this page, click here.
