Paul deals with the full range of private client matters but has particular specialisms in estate planning, restructuring of trusts, and tax mitigation for high net worth individuals. He also acts as a professional trustee and executor and as a professional mediator.  He has been a private client specialist for more than 25 years and has led the private client teams at two different Manchester firms prior to joining Private Client Solicitors. Clients particularly value his breadth of knowledge and experience, and his ability to bring his professional judgement to bear on his client’s affairs.  They also value his ability to deal with all aspects of an assignment from beginning to end – devising a solution to a problem, preparing and, if appropriate, registering the appropriate legal documents, and preparing and filing any necessary tax returns.

Apart from being a solicitor, Paul is a Chartered Tax Adviser and a member of the Society of Trust and Estate Practitioners.  He is a registered mediator and (in the dim and distant past) qualified as a Chartered Accountant prior to ‘seeing the light’ and joining the legal profession.  On the tax front, his primary focus is on inheritance tax but he is able to advise across the full range of private client taxes as they apply to both individuals and trustees, whether UK resident or non-resident, including income tax, capital gains tax, and stamp duty land tax.

Above all else Paul enjoys the challenge of getting to grips with a particularly thorny problem.  That could involve analysing a pile of trust documents to provide a solution for trustees who are in a difficult situation, pulling together a set of complex trust or estate accounts from basic financial information, or helping to devise a tax mitigation strategy tailored to a particular client’s circumstances.    His view is that 90% of seemingly insoluble problems have a solution if you are prepared to be sufficiently inventive and adaptable.  He is often praised for his ability to explain complex matters to clients in a way they can understand.

Paul has undertaken a number of subsidiary but complementary roles during his professional career.  He has acted as an examiner for the Chartered Institute of Taxation, as a guest lecturer on Principles of International Law for the University of Manchester business school.  For several years he was an editor of Ray & McLaughlin’s Practical Inheritance Tax Planning, and contributed technical notes and technical queries for Lexis.  He has also run a paralegal training course on wills and estate administration.

Paul is married and has two grown up children and a dog.

Paul was instructed to review an offshore asset holding structure created some years previously by a well known London private client firm for a UK resident non-domiciled individual, and to advise on how funds could be made available to the individual and his ex-wife in the UK in the most tax efficient way. Paul was then called on to defend a challenge by HMRC to the individual’s non-domiciled status which he did successfully. Paul was subsequently instructed to update the client’s UK will in the light of his divorce, liaising as necessary with lawyers in the country of the individual’s domicile.

Paul was instrumental in the implementation of a high-value gifting plan, in conjunction with the tax-efficient restructuring of two family trusts established some years ago by a high-net worth individual, with a view to mitigating inheritance tax. The plan involved working alongside a ‘Big 4’ accountancy practice and tax counsel, and instructing lawyers in Spain, USA and Scotland. Paul was appointed as a trustee of the family trusts, as a joint executor of the wills of the individual and his wife, and as a joint attorney for the financial affairs of the individual and his wife.

Paul was instrumental in the tax-efficient extraction of funds from an offshore trust established by a UK resident individual, together with the simultaneous creation of a number of family investment companies as asset holding vehicles for the children of the individual concerned. The role involved working alongside tax counsel, a ‘Big 4’ firm of accountants, offshore lawyers, and offshore professional trustees.

Paul was instructed by the trustees of a high-value foreign settlement which had ended on the death of its main beneficiary. An ambiguity about how the burden of inheritance tax payable by the trust would be suffered by the different beneficiaries had to be resolved. Paul also had to liaise with the solicitor acting for the executors of the deceased life tenant, prepare the appropriate IHT account for the trustees, and advise concerning the correct amount of IHT to be paid by the trust.

Paul was asked to assist with the administration of the estate of a couple who had died in quick succession, who had very complicated personal circumstances including property held abroad via an offshore company and various business interests.  The estate also included a ‘home loan’ inheritance tax planning scheme.  Paul was able to deal with all aspects of the arrangements, obtain the relevant grant of probate, and assist with the sale of the assets for the benefit of the beneficiaries.

Paul was asked to advise the trustees of an offshore trust.  The principal beneficiary had died and the new beneficiaries were UK resident.  Paul advised on how the trust could best be restructured in the light of the changed circumstances, having regard to the different tax rules applicable to the new beneficiaries, and supervised the restructuring process.  The process involved the ‘repatriation’ of the trust to the UK including the appointment of Paul as one of the future trustees.

Paul was asked to assist the trustees of an offshore trust, the main beneficiary of which had died.  The estate of the deceased individual was subject to an Inheritance Act claim.  The trust held assets in the UK and the trustees were concerned that they had not complied with their compliance obligations and that various taxes and penalties may be due.  Paul provided a complete analysis of the situation and by working with the trustees was able to find that the situation was not as problematic as previously feared, that all taxes due had in fact been paid and there were not outstanding compliance obligations.

Paul was asked to assist the offshore owners of a number of rental properties in the UK who wished to incorporate their rental business.  Paul was asked to provide a complete analysis of the tax consequences of incorporating the business.  This included obtaining advice from the stamp duty office about the stamp duty payable on the incorporation.  Working with colleagues Paul was able to deal with the transfer of the properties to a new UK resident company including dealing with the property transfers, and reporting and paying all relevant taxes.

Paul assisted the trustees of two trusts who were in dispute with a beneficiary of the trust.  Paul was able to provide advice about the rights of the beneficiary, and the information to which he was entitled and to advise concerning the obligations of the trustees concerning the liquidation of a company that was an underlying trust asset.  Paul then prepared a comprehensive set of trust and estate accounts covering a period of eight years which were acceptable to the solicitor acting for the beneficiary.

Paul was asked to advise an Italian law firm who were acting in the divorce of a very wealthy individual.  The assets subject to division included significant assets held in an offshore trust.  Unfortunately the legal issues around the trust were acting as a barrier to a successful outcome.  Paul was able to advise on a ‘way through’ the issues that ultimately proved acceptable to all parties, allowing the trusts to be unlocked for the benefit of the ultimate client.

Paul was asked by a firm of independent financial advisers to review a trust arrangement in which the firm had been involved many years ago, which had become a cause for concern.  Paul was able to advise about the tax consequences of the arrangements which were not as previously anticipated.  Paul was able to provide a solution to this issue, which involved (a) a restructuring of one trust and (b) an application to court in the Isle of Man for a declaration concerning the second trust.  Paul supervised the application to court in the Isle of Man by lawyers in that jurisdiction, and provided the necessary expert evidence on tax issues by witness statement, ultimately resulting in an amendment to the relevant trust document so that it had the tax consequences that had been expected.

Paul Davies