Paul Beausang advises clients on a broad range of cross-border corporate tax and structured transaction tax matters, issues, with a particular focus on structured finance and real estate transactions. Paul has also been active in advising UK local and municipal authorities on structuring their residential and commercial property holdings to optimise delivery of affordable housing and regeneration.
Paul has advised on devising innovative solutions and structures to minimise unnecessary 'leakage' and maximising efficiencies both in terms of tax payable and timing of tax payments, including in relation to interest withholding taxes, deductibility, sales taxes (e.g. VAT), entity taxes, capital taxes, document taxes (e.g. stamp duty), profit extraction, advising on specialist regimes such as the securitisation company tax regime and the associated HM Revenue & Customs guidance, and drafting and issuance of tax opinions as part of the achievement of ratings from the leading rating agencies, and obtaining rulings and advance clearances from HMRC.
Paul has also structured significant direct and indirect real estate investments, including joint ventures, developments, disposals and refinancings and is familiar with the use of SPVs (including offshore unit trusts, companies, limited partnerships and co-investment structures) as well as the principal UK property tax issues arising in their use.
Prior to joining Morgan Lewis, Paul was a partner in the tax practice of another international law firm. He previously qualified as a tax consultant in 1997 and as a lawyer in 2002. Paul was also a tax consultant at a Big 4 accounting firm in the past.
Advising on the tax issues flowing from the establishment of a structured finance platform to facilitate efficient multi-investor segregated investment programmes, including liaising with HMRC and obtaining rulings on complex issues relating to the nature of the securitisation cashflows.
Advising on the structuring and development of a local authority residential redevelopment and structuring the same to allow for the development funding to be provided on a capital markets basis.
Advising a range of indirect property funds on the implications of the introduction of SDLT and the exporting of these funds to Jersey (more than £2.5b of UK property fund value).
Advising offshore joint venture investors on establishing UK operating businesses and on UK tax structure drivers including VAT, permanent establishment, transfer pricing and double tax treaty relief.
Advising a joint venture in relation to a complex real estate property assembly with a view to facilitating a redevelopment of a c. £1bn City office site, including SDLT and VAT analysis on land exchanges, contingent ratcheted overage rights and partnership transactions.
Dublin City University, 1994, Prof. Diploma in Accountancy
University College Dublin, 1993, BC.L.
England and Wales (Solicitor)
Awards and Affiliations
Member, Practice Group of the Year, Tax, Law360 (2017)
Recommended, Corporate Tax, The Legal 500 UK (2017)
Recommended, Social Housing: Finance, The Legal 500 UK (2015)
Associate, Irish Tax Institute
Member, Stamp Taxes Sub-Committee, The City of London Law Society’s Revenue Committee
Member, Tax Panel, Association of Real Estate Funds