As the world changes, so do the tax challenges faced by businesses. From the smallest start up to the largest multinational, both their tax positions are impacted by the manner in which business is conducted and the regulatory environment. However, tax can also play a significant role in how those businesses operate and are structured. In particular, changes caused through digitalisation have had, and continue to have, a major impact on the business tax environment.
Our Tax Group has a wealth of experience in advising businesses in our core sectors on their tax issues, whether those are wholly domestic or international. Such advice is often multi-disciplined, involving our corporate, commercial, finance, IP and regulatory colleagues and includes advising on:
- structuring business activities, ranging from advice on the initial establishment of companies or partnerships and the holding of shares to the structuring of large international groups;
- the tax aspects of group reorganisations and demergers often in conjunction with our specialist corporate colleagues;
- the holding and exploitation of intellectual property and research and development activities, including the impact of group structuring on IP amortisation, withholding taxes, and tax incentives such as patent box and R&D relief;
- transfer pricing arrangements;
- the structuring of debt funding and share capital;
- tax incentives for growth companies, including advising on the conditions in the UK for EIS and VCT qualifying company status;
- supply chain structuring;
- VAT issues, often in respect of cross border supplies of goods and services;
- tax issues in insolvency situations; and
- tax disclosure regimes, including UK DOTAS and DAC6
We draw on our experience across our Tax group on these assignments. As well as our business tax lawyers, we are also able to bring in the expertise where relevant of our Private wealth, Incentives and Tax disputes teams. We work closely with specialist firms where necessary to deliver the best services to our clients, for example in respect of valuations, accounting, transfer pricing advice and R&D tax claims.
We acted for a large international provider of e-commerce services on the reorganisation of its international structure, including advice in UK and Netherlands.
International supply chain
We act for an Australian business selling goods in the UK on the UK tax aspects of its international supply chain
We acted for a provider of transportation services on reorganising its group structure in UK and Ireland
We acted for a life sciences company in a group reorganisation, separating its regulated and unregulated activities in UK and US
Illuminate Financial Management
Advised VC firm Illuminate Financial Management on the final close of their second fund at $100m.
Morrison & Co
We advised Morrison & Co on the acquisition of a majority interest in Fore Freedom Holdings B.V., a fibre-to-the-premises network business in the Netherlands, from funds managed by Ancala Partners.
We advised Global Student Accommodation Group on the acquisition of two purpose built student accommodation assets in Bristol alongside joint venture partner, Harrison Street.
We advised Miniclip on its acquisition of the independent mobile games developer Mobile Gaming Studios, which trades as Eight Pixels Square.