Tax is an essential focal point for businesses. It has the potential to impact all aspects of day-to-day operations, from meeting compliance obligations to understanding the issues that arise when buying or selling a company, or undertaking bespoke planning for a complex capital reorganisation.
We provide practical, cost-effective tax advice that’s tailored to the exact needs of your business, delivering valuable savings to you wherever possible. You will benefit from a wealth of expertise in strategic planning, since our team’s knowledge spans a broad range of business sectors. There is a particular focus on “bridging the gap” between the ever-increasing complexity of tax laws around the world and your particular commercial needs.
We can advise you on the corporate tax and employment income tax aspects of a wide variety of matters, including domestic and cross-border M&A and structuring and restructuring, real estate, private equity and venture capital, investment funds, finance (including Islamic finance, asset finance and other niche areas), intellectual property, insolvency, and tax disputes.
Areas of expertise
- Banking taxation
We work closely with our Finance team to advise on all taxation implications arising from projects work and funding structures including the following:
- Taxation issues regarding the financing of acquisitions and the refinancing of existing investments.
- Transfer pricing/ thin capitalisation issues arising from debt financing, and withholding tax and deductibility issues concerning interest and other payments made in relation to such debt financing.
- Taxation issues arising from limited recourse financing and hybrid debt arrangements with equity features (eg, convertible debt).
- Corporate tax
We provide an integrated service with our Corporate lawyers on a wide range of transactions, advising on tax-efficient structuring and assisting with the drafting of documentation to allocate tax risks between parties in the agreed manner. Our expertise includes the following:
- Corporate re-organisations, restructurings & demergers
- IPOs & secondary offerings
- Inward investment
- Joint ventures
- Mergers & acquisitions
- Partnership structures
- Employee incentives
We try to achieve the most tax efficient arrangements for companies wishing to incentivise their employees and directors, and indeed for the employees and directors themselves. We work closely with our specialist employment and corporate lawyers. However, our work is not limited to pure tax issues. The design and implementation of share schemes (and advising on methods of incentivisation using direct share ownership) involves considering issues ranging from the accounting impacts of the proposed arrangements to securities laws and financial assistance issues.View all our Employee incentives experts
We have extensive experience in advising both private and public companies on the most beneficial structures to put in place to incentivise staff. Furthermore, we advise on employee incentives and taxation in connection with the events occurring in a company’s development from incorporation, to VC or private equity funding, to merger or acquisition and IPO.
Our advice covers: UK employee incentives; bespoke option arrangements; corporate governance; incentives in relation to employment issues; equity incentive arrangements; inward investment; Income Tax and National Insurance Contribution issues; scheme design and implementation; and transactions.
Find out more about Employment work
- International taxation
We offer a full range of business tax services, advising domestic and multinational companies, owner-managed businesses, investors and entrepreneurs on a wide range of corporate, finance, intellectual property and real estate transactions. Our international tax team provides expertise in all our jurisdictions in Europe, the Middle East and Asia. We also have an established network of “Best Friend Firms” with whom we frequently work in other jurisdictions. This structure ensures that we are equipped to handle a variety of multi-jurisdictional, cross-border tax transactions. We provide high-quality, cost-effective and innovative tax solutions tailored to the needs of our clients and their businesses, delivering valuable savings wherever possible.View all our International taxation experts
- Media & IP taxation
We advise a wide range of clients operating in the media & IP sectors (including in the fields of broadcasting, film and software publishing, and gaming) on the tax issues they face. For example we regularly advise on:
- E-commerce and payment services.
- International withholding tax issues on the exploitation of broadcasting rights and other intellectual property.
- Film investment and funding (including sale and leasebacks and other tax-based funding mechanisms and investment vehicles).
- Image right structures for sportsmen and entertainers.
- Optimal structures for the holding of intellectual property assets.
- Private client tax planning
We have a large number of specialists in all aspects of personal taxation. Such private client tax planning includes all aspects of inheritance tax, capital gains tax, income tax, real estate transfer tax and, in the UK, stamp duty land tax. We can also advise personal and business clients on the use of double tax treaties. We add value to our clients’ activities, advising on effective tax planning from hostile and contentious claimants, and from problems arising out of succession issues.View all our Private client tax planning experts
Find out more about our Private Client work
- Private equity & venture capital taxation
We work closely with our private equity team advising on the most tax-efficient method of structuring and implementing private equity and venture capital transactions. We have considerable experience of advising institutional investors and structuring leveraged transactions to meet the particular needs of private equity funds.View all our Private equity & venture capital taxation experts
We also have wide-ranging experience on important issues such as identifying the most suitable share option and/or incentivisation packages for management, or the most tax-efficient forms of financing whether debt, equity or a mixture of the two and, where debt is involved, the structuring of that debt. We will also advise on the structuring and establishment of private equity funds, including arrangements for management “carry” and other forms of participation. Specific to UK venture capital investments we advise Venture Capital Trusts on their tax issues including, whether the investment in the investee company is a qualifying holding for VCT purposes. We also advise on the eligibility of the investee company and its shareholders for Enterprise Investment Scheme relief.
- Real estate & construction taxation
We have a very close working relationship with our real estate, planning and construction teams to advise on the tax implications of transactions and arrangements, and structures to maximise efficiency in the real estate sector. We are particularly noted for our work in inward investment into UK real estate from abroad, both in relation to tax efficient planning of their acquisitions and disposals, and the ongoing UK tax implications of investments. We are also noted for our work in the hotels and leisure industry. We advise on both the direct and indirect tax treatment of transactions, and are experienced in structuring to mitigate stamp duty land tax and VAT. We also advise on tax issues arising in connection with capital expenditure, including maximising the availability of capital allowances and addressing the construction industry scheme where relevant. We will support clients on land transfer and registration tax planning (including implementation of mitigation structures).View all our Real estate & construction taxation experts
- Tax disputes & litigation
We provide support and advice for clients involved in disputes with HM Revenue & Customs, in tandem where appropriate with colleagues in our dispute resolution team. We also advise on disputes between commercial parties, for example in relation to warranty or indemnity claims relating to tax.View all our Tax disputes & litigation experts
- Taxation on transactions
Working with our Corporate group we develop tax-efficient solutions for domestic and cross-border transactions, including:
- Share & asset acquisitions: we advise on all aspects of mergers and acquisitions to ensure tax-efficient structures are implemented.
- Funding structures for acquisitions: we review funding structures to ensure maximum tax relief is obtained for costs of borrowing.
- Venture capital & other private equity funds: we ensure such structures are efficiently structured and compliant with any particular legislative regimes.
- Transfer pricing issues: we anticipate and advise on issues arising on the pricing of cross-border transactions.
- Corporate re-organisations, reconstructions & demergers: we ensure these are structured tax efficiently.
- Management buy-outs & buy-ins: we advise management on tax-efficient remuneration structures and equity participation.
- Optimising reliefs: we review existing loss situations with a view to ensuring maximum utilisation of relief.
- Structuring emigration & immigration of companies & individuals: we advise on tax-efficient structures for offshore tax planning.
- Leasing transactions: we review lease structures to maximise the tax benefits available.