Overview

Our expert lawyers provide corporate tax advice to companies and their shareholders, ensuring our clients make tax-efficient and yet commercially beneficial decisions for their business. We offer a range of corporate tax advice, including tax-planning for shareholders and their companies, tax efficient group structuring and restructuring and tax-efficient disposals.

We work closely with our private client lawyers to advise privately held groups to ensure that the personal tax position of individual shareholders is aligned with that of their companies. Similarly, we work with our corporate team to provide corporate tax advice relevant to company law issues and to deals. With support from leading local counsel, we can provide corporate tax advice across multiple jurisdictions.

All of our lawyers are qualified solicitors and most are chartered tax advisers (CTA).

Areas of focus

We provide expert corporate tax advice for companies and their shareholders, including the following:

  • General corporate tax advice including SSE, intangibles and degrouping issues.
  • Group structuring and restructuring.
  • Cross-border transactions and international holding company structures.
  • Evaluating the risk profile of tax planning strategies.
  • Inward investment for trading land investment and land development projects.
  • Entrepreneur's relief on disposals.
  • EIS, SEIS and VCT advice.
  • Tax efficient employee incentives and the implications for shareholders on an exit.
  • Structuring groups for maximising operational and disposal benefits.
  • Minimising the overall tax burden on trading profits.
  • CFC, DPT, hybrid, restrictions on deductibility of interest and associated structurings.
  • Advice on tax issues arising from blockchain and battery energy storage technology.
  • Planning for a tax-efficient exit of shareholders.
  • Passing shares down to the next generation in a tax-efficient way.
  • Residence and permanent establishment advice.
  • Double tax treaty issues.
  • Tax relevant to administration and insolvency procedures.
Experience

Advising 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."

Advising an American company looking to fund the acquisition of a UK and Irish group on the application of the worldwide debt cap rules.

Advising 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.

Advising 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.

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.

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.

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.

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.

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.

Meet the team
Nigel Popplewell

Nigel Popplewell Partner

  • Corporate Tax
  • Tax
  • Real Estate Tax
Ian Carnochan

Ian Carnochan Partner

  • Tax
  • Corporate Tax
  • Real Estate Tax
John Barnett

John Barnett Partner

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

Tax Advice for Companies and Shareholders

Market-leading team providing high-quality tax planning advice on property transactions and corporate restructurings.
Chambers UK 2018