Leigh Sayliss
After almost 20 years in engineering, Leigh retrained and requalified as a solicitor in 2003. He joined Lawrence Stephens in 2025.
Leigh is a versatile Tax Partner and Chartered Tax Advisor with wide experience in property, corporate and employment taxes in particular.
Leigh maintains a broad practice and enjoys the challenges created by the ways in which different taxes interact in real-life situations—looking for practical solutions for his clients.
Leigh uses his experience as a professional engineer and his background in industry to help him bring a commercial understanding to the transactions with which he is involved.
Leigh is editor of the land-related sections of “Monroe and Nock on the law of Stamp Duties”. He is chair of the CIOT Property Taxes Committee and a member of HMRC working groups in relation to Stamp Duty Land Tax and construction matters.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2003
Experience
- Memery Crystal (Feb 2022 - Mar 2025)
- Howard Kennedy (Jan 2015 - Jan 2022 )
- Stephenson Harwood (Nov 2005 - Jan 2015)
- Hammonds (Aug 2001 - Nov 2005)
Membership
- Fellow of the Chartered Institute of Taxation
- Chair of the Chartered Institute of Taxation Property Taxes Sub-Committee
- Council Member of Stamp Taxes Practitioners’ Group
- Chartered Engineer, Member of the Institution of Engineering and Technology
Qualifications
- Bar Vocational Course (Postgraduate Diploma) (2001)
- Batchelor of Laws (First Class Honours) (2000)
- MA, Electrical Sciences (1988 (BA Hons – 1984))
Education
- Inns of Court School of Law (2000 - 2001)
- University of Hertfordshire (1996 - 2000)
- University of Cambridge (1981 - 1984)
3 Contributions by Leigh Sayliss
PRACTICE NOTES
Direct tax in UK residential property development: investment versus trade, holding structures, offshore, transactions in land, RPDT, ATED, CIS
Property development
Within the real estate arena, development activity is fundamental for all participants, whether they are specialist developers or owners enhancing their own investment properties. Projects may range from light refurbishment and substantial alterations through to entirely new construction. Although those undertaking these activities are typically taxed under the ordinary rules, certain provisions apply specifically to property development. Development can be for commercial purposes, for residential use, or a mix of both, for example where flats are created above commercial space at street level. Many of the issues arising for commercial and residential schemes are similar, though notable differences do exist. For any project, it is necessary to evaluate indirect tax as well as direct tax. This Practice Note looks at the direct tax considerations that arise in particular on the development of land for residential use. The focus is on landowners developing their own land, rather than construction companies that undertake building work without holding an interest in the land being developed. The indirect considerations...
Tax
PRACTICE NOTES
UK direct tax for commercial property development: investment vs trading, appropriations, holding structures (including offshore), transactions in UK land rules, profit computation (corporation and income tax), capital allowances and CIS.
Property development sits at the heart of what everyone in the real estate industry does, from dedicated developers to owners improving their own investment assets. Projects may span light refurbishment and significant remodelling right through to ground‑up builds. Participants are mainly taxed under the ordinary regime, although certain rules are tailored specifically to development. Schemes may deliver commercial premises, dwellings, or mixed‑use outcomes, for example flats above shopfronts at pavement level. Many of the issues overlap across commercial and residential schemes, though material distinctions also arise. Any project must address indirect taxes alongside direct tax questions. This Practice Note examines direct tax matters that arise specifically on commercial land development. Its focus is the position of landowners developing their own sites, rather than contractors delivering works without a proprietary stake in the land. It also encompasses investors enhancing their holdings as well as specialist developers operating across the market. Work may comprise modest upgrades, extensive alterations, or the creation of entirely new structures. In broad terms the mainstream tax regime applies, with extra measures directed at development activity. Mixed‑use cases often place flats above retail or other trading units at street level. Key differences still persist.
The indirect tax considerations
...
Tax
PRACTICE NOTES
UK Property Transactions: Distinguishing Trading from Investment, Tax Consequences, HMRC Enquiries, Mixed Motives and Tenant Transactions in Superior Interests
Practice Note
The tax outcome for the owner hinges on whether a property is bought, retained or sold as an investment or as part of a trading (ie dealing) venture. Land, more than many other asset classes, can be kept as an investment or treated as trading stock, and the correct classification turns on each party’s particular position—the identical deal may amount to investment for one participant and trading for someone else. This Practice Note sets out the main factors used to differentiate trading from investment activity in relation to property. Those factors apply equally to transactions yielding gains and those producing losses. It also explains HMRC’s stance when opening enquiries into whether a property deal is trading or an investment in nature. It further addresses particular situations, such as mixed-motive transactions, taxpayers both dealing and investing, and tenants transacting in superior interests in land...
Tax
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