Corporate tax 

Our Corporate Tax group advises quoted and privately owned companies and the people who run them.

The group provides a wide range of commercial taxation advice - both transactional and pure advisory. This includes company acquisitions and disposals, corporate reconstructions, venture capital transactions and indirect tax planning. In particular, we have built up an extensive track record and a reputation for advising on the tax challenges faced by serial entrepreneurs and privately owned companies at shareholder level, director and employee level and at company level.

Much of the group's work involves overseas aspects - advising overseas companies and executives (or their professional advisers) on UK tax issues such as UK double tax treaty interpretation, cross-border employee incentive schemes and offshore tax planning structures. For businesses setting up in the UK, we offer a full corporate service from incorporation to sale, identifying commercial needs and objectives to achieve a fully tax-efficient corporate structure within a global context.

Our involvement in business sales starts at the pre-sale planning stage and continues through to negotiating the tax aspects of the sale with the purchaser's solicitors. For sales with overseas connections we will also devise and implement share reconstructions and pre-sale reorganisations. We regularly advise companies on structuring issues prior to third party investments, including VCT and EIS requirements.

We provide specialist tax advisory services both to clients and to other professional advisers here in the UK and overseas - in particular on technical issues raised by or in dispute with HM Revenue & Customs. We have experienced recent success against HM Revenue & Customs before the Tax Tribunals.

The depth of our service aims to add value to our clients, and as such all our tax services are boosted by our highly regarded practices across business services, employment and private client, real estate and construction.

We regard ourselves as different from other tax advisers. Providing pragmatic advice, we know how important it is that clients understand the consequences of their deal or project. To this end, we make sure to understand a client’s business inside out and present the facts realistically, relevantly and in plain English.

Experience

Demergers and corporate restructuring
Advising on the taxation aspects of the demerger of a leading management consultancy's ventures business into a new private equity fund structure by way of Court approved scheme of arrangement and section 110 liquidation reconstruction.

Reorganisation of investment management group
Advising an investment management group on its conversion to an LLP, and the increase of the management team's interest in the business.

Privately owned property group – partition and restructuring
We advised the shareholders of a privately owned property investment and dealing group on the partition of the group under Section 110 Insolvency Act 1986, including securing tax clearances for the tax free partition at corporate and shareholder levels.

Venture debt – restructuring
Tax advice on the complex restructuring of a leading venture debt provider involving the creation of a new overseas investment vehicle, the preparation of the investment prospectus, the negotiation of terms with equity providers, the negotiation of a senior debt facility and the negotiation of management terms.

Property fund – tax planning
Advising a UK property manager on the creation of a property investment fund including feeder funds and parallel funds to accommodate different investor requirements.

CDO securitisations
Advising on securitisations with an aggregate value of US$10.5 billion.