Business

Tax

Corporate tax planning

We provide tax efficient strategies for corporate transactions and real estate investments, working with domestic and multi-international businesses, both publicly and privately owned. For many of our clients the real value in the deal comes from structuring it tax efficiently, in areas such as:

  • Pre sale and/or IPO tax planning for entrepreneurs and/or management
  • Mergers and acquisition tax advice
  • Partnership, corporation and other entity planning
  • Licensing/sponsorship agreements
  • Structuring of IP rights & loyalties

We advise regularly on cross-border mergers, acquisitions and disposals; choice of legal/tax entity and the establishment of business operations in a foreign jurisdiction; the cross-border licensing of intellectual property; and the formation of holding companies based offshore or in jurisdictions such as the Netherlands, Luxembourg, Sweden or Switzerland.

Recent work

  • Acting for the CEO of a new confectionary company in his acquisition of a significant equity stake. This company was the franchisee of a large US operation which was determined not to lose its brand control. We successfully managed to:
    - Protect him in his commercial position as a significant minority shareholder and employee;
    - Minimize his potential to UK income tax on his incentive package;
    - Ensure there were no adverse US tax consequences arising as a result of his US citizenship.
  • Advising on international corporate structuring for CIS-based companies prior to IPO in the oil, gas and telecoms sectors.
  • Assisting a private equity fund in respect of investment in a major Russian transportation company through a Swedish holding vehicle.
  • Providing counsel on the optimal international tax structuring of real estate projects in Kazakhstan.
  • Advising on the availability of the participation exemption in the Netherlands for inbound dividends and capital gains. 
  • Advising a US based multinational corporation on the structure of its worldwide manufacturing and distribution network.
  • Advising various UK- and Italy-based corporations on business operations in the US. 
  •   Advising US group of corporations on restructuring within a worldwide group with a view to foreign country IPO. 
  • Structuring investment transaction to preserve ownership position of US executive (a founding shareholder) of newly-public European company to satisfy major supplier agreement covenant 
  • Advising a UK-based boutique hotel/club on funding of US operations and redemption of UK and US investors.

© Withers 2007 - 2008