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.
Contributed to

8

Interaction of EU law and direct tax
Practice Note

This Practice Note looks at the interaction between EU law and the direct tax rules of Member States, particularly where potential incompatibility between the two is referred to the EU Court of Justice. It also looks at the key questions when considering whether a national tax provision is compatible with the fundamental freedoms, including the potential justifications for restricting a freedom. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

Overpaid tax—EU law and restitution
Practice Note

This Practice Note is about the rights of a person who has overpaid tax to recover that amount under EU law and common law (specifically the law of restitution). It covers the application of the law of restitution to direct taxes, including Woolwich claims and mistake-based claims, and the related rules on limitation periods. It also covers the application of EU law and the law of restitution to overpaid VAT. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

Overpaid tax—interest and damages
Practice Note

This Practice Note is about the right to interest on repayments of overpaid tax, whether under a statutory regime, EU law, or the common law (and specifically the law of restitution). It covers direct taxes and VAT. This Practice Note also discusses the corporation tax charge on restitution interest, and EU law on whether overpaid tax may give rise to a right to damages. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

Overpaid tax—the statutory regimes
Practice Note

This Practice Note is about the statutory provisions regulating the recovery of overpaid tax. In the case of direct taxes, it covers overpayment relief. In the case of VAT, it covers the rules applying to a taxable person who has either paid too much output tax or recovered too little input tax. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

Sukuk—investment bond arrangements and UK VAT
Practice Note

This Practice Note on Islamic finance and tax outlines the UK VAT treatment of the issue, transfer and redemption of sukuk by an issuer belonging for VAT purposes in the UK. It also considers who the supplier is for UK VAT purposes in dealings by the issuer with the sukuk trust property. This Practice Note was produced in partnership with Étienne Wong of Old Square Tax Chambers.

Taxation of cryptoassets
Practice Note

This Practice Note outlines how the UK treats cryptoassets for income tax, capital gains tax (CGT), corporation tax, stamp duty reserve tax (SDRT), stamp duty land tax (SDLT) and VAT purposes. In this Practice Note, the term ‘cryptoasset’ is used as a generic term for cryptocurrencies, virtual currencies, virtual assets or digital tokens/crypto tokens.

VAT bad debt relief
Practice Note

This Practice Note outlines how a taxable person who has accounted for and paid VAT on a supply, but who is not paid the price for that supply, may claim a refund of the whole or part of the VAT that they have paid. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

VAT—European legal principles
Practice Note

This Practice Note is about the impact of EU legal principles on the implementation and application of VAT law in EU Member States. It also describes the possible consequences where Member States have failed to implement the VAT Directive in a manner that conforms with these principles. This Practice Note was produced in partnership with Etienne Wong of Old Square Tax Chambers.

Practice areas

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