Tax Advice for Companies and Shareholders Experience
Distributions to Holding Companies
Advice to an international group of companies on the application of the dividend exemption in circumstances, including in particular whether the dividends formed part of a "UK tax advantage scheme."
Worldwide debt cap - acquisition of UK and Irish group
Advice to an American company looking to fund the acquisition of a UK and Irish group on the application of the worldwide debt cap rules.
Substantial Shareholding Exemption
Advice to a group of companies trading in pharmaceutical products and its shareholders on the application of the substantial shareholding exemption to liquidations made in the course of a group restructuring.
Structuring development finance
Advice to a member of a property joint venture regarding structuring development finance to ensure tax deductibility of finance costs, the surrender of losses and the VAT implications of providing management services.
Pre-IPO advice
Advising offshore trustees holding shares in a UK group of companies on a proposed restructuring of the group prior to a proposed IPO on AIM.
Group restructurings
Advising on a reconstruction of a property holding company worth approximately £60 million using a liquidation scheme under section 110 of the Insolvency Act.
Advising on a group restructuring intended to secure inheritance tax business property relief on shares in the group holding company.
Company tax structuring
Providing tax structuring advice in respect of the sale of a large number of garden centres to a company with a diverse array of shareholders for whom the tax implications of the sale were complex and varied.
Reorganisation of property owning companies
Advising the administrators on the reorganisation of a number of property owning companies in which the legal and beneficial ownership of the properties was split, including the effect of the administration on the grouping of the companies for VAT, SDLT and corporation tax purposes.
Advice to care home company
VAT advice to a joint venture set up to provide care homes with extra care facilities where supplies were made to and by the joint venture partners.