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.
We are also well-versed in issues concerning the cross-border flow of capital, the use of hybrid entities and financial instruments, and the maximization of foreign tax credits and benefits.
Additionally, we provide tax planning advice to clients with regard to IPOs on the main market of the London Stock Exchange and on AIM. Our team has particular experience in advising CIS-based companies in preparation for IPO in London.
Our clients are worldwide, based in North America, Europe and Asia, and especially in the CIS region: we work for many companies in Kazakhstan, the Russian Federation, Kyrgyzstan and Georgia. The client list includes major banks, insurance companies, property finance clients, hotels and luxury brands, and fund managers, and we have particular experience of the mobile telecoms, oil and gas, construction, mining and transportation sectors.
- 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.