Overview

As UK tax law becomes increasingly complex, businesses and individuals need specialist tax lawyers able to identify the risks and opportunities, and to help them ensure compliance. Our tax lawyers have comprehensive knowledge of UK tax law, and deep sector insight, providing the highest level of legal advice to our clients.

Featuring a number of chartered tax advisers, our tax law team is renowned for delivering creative and effective solutions to clients across a range of industry sectors. Our clients range from corporate entities and trusts to charitable bodies, as well as individuals domiciled in the UK and abroad.

In an ever-shifting legal landscape, our expert tax lawyers understand that it’s essential to quickly identify, and respond to, changes in UK tax law. The outstanding reputation of our team is reflected in our membership of national committees such as the Chartered Institute of Taxation Technical Committee and Law Society Tax Law Committee. The team's quality was further recognised at the Tolley's Taxation Awards 2016/17, at which – against competition from both accountants and lawyers – we won the award for Best Team in a National Firm.

Areas of focus

Our tax law expertise includes the following:

  • Compliance and disclosure.
  • Contentious tax law matters, including in relation to cross-border assets and offshore trusts.
  • Advice to private individuals including those with an international connection in relation to their UK tax position, often involving the interaction of business and personal affairs.
  • Mediation between taxpayers and HMRC.
  • Advice and representation for clients undergoing investigation.
  • Tax planning and advice related to business property and share transfers, and corporate restructuring.
  • Negotiating and drafting documents dealing with tax risk.
  • Tax advice and drafting relating to financing arrangements.
Experience

Advising the Co-operative Group on the sale of their farming business with a value of approximately £250 million. The assets (mainly real property) were hived down into a subsidiary prior to the sale and we advised on and negotiated the tax provisions relating to that hive down, mainly in relation to the VAT and SDLT treatment of the properties and on the tax provisions in the sale agreement with the ultimate purchaser.

Advising a BVI based private equity fund in relation to their investment in UK real estate through Jersey SPV's. Providing tax advice on these investments, covering the whole spectrum of tax including income tax, artificial transactions in land, land dealing, corporation tax, central management and control, permanent establishment issues, VAT, stamp taxes, capital allowances and withholding tax advice.

Advising clients on the way the Finance Act 2014 legislation relating to Follower Notices and Accelerated Payment Notices might be impugned either by way of judicial review or by way of proceedings through the European Court of Human Rights.

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 employees' / employers' national insurance contributions.

Advising Charterhouse (Accountants) LLP 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.

Advising 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 on the VAT implications of restructuring its facility management services arrangements, worth £13 million p.a. for the UK and Northern Europe.

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 £140,000 of income tax and national insurance contributions.

Acting on a reconstruction of a property holding company worth approximately £60 million using a s110 liquidation scheme.

Advising 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 after HMRC had raised an assessment for significant sums of income tax and national insurance contributions and successfully negotiating an acceptable settlement.

Advising management teams, venture capitalists (eg ECI) and selling shareholders for deals worth in excess of £250 million – including advice to the institutional management shareholders of Bounty Group Limited on the sale to Kaboose Inc (a Canadian media company) for £70 million.

Advising Absolute Capital Management, a fund management company, on its acquisition of the hedge fund business of debt fund manager Argo Capital Management for £50 million.

Advising RWE Npower 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.

Advising the Longman family on the reconstruction of a group of farming companies worth approximately £7.5 million 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.

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.

Meet the team
Nigel Popplewell

Nigel Popplewell Partner

  • Corporate Tax
  • Tax
  • Real Estate Tax
Jim Aveline

Jim Aveline Partner

  • Private Client Services
  • Family Offices and Family Businesses
  • Food and Farming
John Barnett

John Barnett Partner

  • Head of Private Client Services
  • Head of Partnerships
  • Tax
Suzanna Harvey

Suzanna Harvey Partner

  • Private Client Services
  • International Tax
  • International Trusts
Tom Hewitt

Tom Hewitt Partner

  • Private Wealth
  • Head of Estates and Land
  • Head of Food and Farming
Beatrice Puoti

Beatrice Puoti Partner

  • Head of Private Wealth
  • Private Client Services
  • International Tax and Trust
Ian Carnochan

Ian Carnochan Legal Director

  • Mergers and Acquisitions Tax
  • Finance and Insolvency Tax
  • Real Estate Tax

What others say...

Premier tax practice which frequently advises clients on free-standing tax matters as well as those relating to corporate and real estate transactions...

Chambers UK 2016