Tax Experience
International Group of Companies
Structuring the payment of an arbitration award in excess of £9 million to an international group to minimise tax liabilities. The award was potentially subject to corporate tax as trading income in three separate jurisdictions, but the total tax liability in all three jurisdictions was reduced to approximately £300,000.
Designing a bonus structure for an executive which allowed a cash bonus in excess of £3 million to be paid entirely free of tax and employee's/ employer's national insurance contributions.
Charterhouse (Accountants) LLP
Advice in connection with the establishment of a series of partnership structures to enable tax efficient profit extraction. This has included setting up partnership between individuals and companies, advice on TUPE and restrictive undertakings, property and other transfer work.
St Modwen Developments Limited
Advice to St Modwen Developments Limited on a series of development projects including the redevelopment of an ex RAF base to be developed into a mixture of high value commercial and residential property.
Advising the Foreign and Commonwealth Office
Advising the Foreign and Commonwealth Office on the VAT implications of restructuring its facility management services arrangements, worth £13m p.a. for the UK and Northern Europe.
A senior manager
Advising a senior manager and negotiating with HM Revenue and Customs in respect of a termination payment on grounds of ill health and successfully reclaiming over £140k of income tax and national insurance contributions.
Reconstruction of a property holding company
Acting on a reconstruction of a property holding company worth approximately £60M using a s110 liquidation scheme.
Advice on insurance premium tax
Advice to a significant insurer in respect of the correct rate of insurance premium tax to be charged in respect of car protection plan policies.
Advising a consultant on a status enquiry
Advising a consultant on a status enquiry after HMRC had raised an assessment for significant sums of income tax and national insurance contributions and successfully negotiating an acceptable settlement.
Private equity disposals and acquisitions
Advising both management teams, venture capitalists (e.g. ECI) and selling shareholders for deals worth in excess of £250m - including advice to the institutional management shareholders of Bounty Group Limited on the sale to Kaboose Inc (a Canadian media company) for £70m.
Absolute Capital Management
Advice to fund management company Absolute Capital Management on its acquisition of the hedge fund business of debt fund manager Argo Capital Management for £50m.
RWE NPower
Advice in connection with the £25.5 million acquisition of a new headquarters building in the north of England, focusing on SDLT mitigation and capture of capital allowances.
The Longman Family
Advising on the reconstruction of a group of farming companies worth approximately £7.5M under a s110 Insolvency Act 1986 scheme of reconstruction, including obtaining a number of non-statutory clearances in relation to the VAT, capital gains tax and stamp duty land tax consequences of the transactions.
VAT on boat chartering
Acting for an individual and his Isle of Man company to recover £400,000 of input VAT incurred on the purchase of a motor cruiser.
VAT on boat chartering
Acting for an individual and his Isle of Man company to recover £400,000 of input VAT incurred on the purchase of a motor cruiser.