Graham Callard

9 Stone Buildings

Graham is a very experienced tax lawyer with over 30 years of experience in firstly the accountancy profession, then the insurance industry. Graham has spent 10 years as an employed barrister providing tax advice for clients of firms of solicitors, and is now practising at the independent bar from 9 Stone Buildings, Lincoln's Inn. As a tax specialist, Graham has principally focussed on the following taxes: income tax, corporation tax, capital gains tax, VAT, inheritance tax, national insurance, stamp duty, stamp duty land tax and more recently ATED.

Practice Area

Private Client

Panel

Contributing Author

Membership

The Honourable Society of the Middle Temple
Member of the Society of Trust & Estate Practitioners (STEP)
Member of the Chartered Institute of Arbitrators ('MCIArb')
The Chancery Bar Association
The Revenue Bar Association

Education

LLB(Hons) ' University of Wolverhampton
LLM ' University of Huddersfield

1 Contributions by Graham Callard

PRACTICE NOTES

UK IHT residence-based regime: excluded property trusts—long-term residence, relevant property charges, QIIP, GWR/POAT, treaty relief and transitional rules from 6 April 2025 (including Budget 2025 cap)

FORTHCOMING CHANGES: At the Budget on 26 November 2025, the government set out minor corrective adjustments to the residence-based tax regime introduced by Finance Act 2025. Key points are: new residents wishing to use the foreign income and gains (FIG) regime must be at least 10 years old at the start of the tax year relief claims under the FIG regime can be offset only against the specific foreign income, foreign employment income or foreign gains to which they relate alignment of the qualifying asset holding company (QAHC) rules so that carried-interest-style returns connected with services to a QAHC qualify for relief under the FIG regime a correction to the capital gains tax (CGT) residence test for personal representatives to ensure they are not UK resident where the deceased was UK non-resident but was a long-term UK resident for inheritance tax purposes a requirement that an individual must file a tax return where they are not entitled to the CGT annual exempt amount under the FIG regime minor changes to the ‘available protected income’ rules and to the transfer of assets abroad provisions, and a transitional protection where those...

Private Client

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