Tax advisers must now understand and advise on increasingly complex anti-avoidance rules, including the new rules which allow the UK tax authority to demand up-front payment of disputed tax where they are challenging a scheme. We strive to achieve what is practical and possible and draw attention to the real risks.
Marc Selby heads our Tax Group, which covers the full range of direct and indirect taxes. We regularly work with colleagues in other practice areas, particularly Corporate, Real Estate, Private Client, Intellectual Property and Employment, to provide practical and commercial solutions. We are also experienced in working with the client’s own advisers, often other professionals who may be solicitors or accountants, in providing technical tax support on transactions and structures on which they are advising.
A significant part of our practice includes assisting other professionals, including solicitors and accountants, on a consultancy basis on the tax aspects of transactions on which they are advising.
We have broad experience of cross-border transactions and expertise in direct and indirect tax matters.
We advise across a wide spectrum reflecting the breadth of our firm-wide practice.
We frequently advise on the tax aspects of:
- corporate transactions and structures, including mergers and acquisitions, de-mergers, reconstructions, private equity transactions and joint ventures
- property transactions and structures, including stamp duty land tax, annual tax on enveloped dwellings, VAT and capital allowances
- remuneration and benefits – employee share and share option schemes, employee benefit trusts, remuneration planning and taxation of expatriate employees (inbound and outbound)
- cross border issues – inbound and outbound
- advising a Guernsey-based Student Accommodation Fund on the capital allowances, stamp duty land tax and VAT aspects of the disposal of its investment portfolio for consideration exceeding £400m, including working with the fund’s solicitors, accountants and financial advisers in negotiating and agreeing the tax provisions of the sale agreement
- advising an English limited partnership fund on the stamp duty land tax and VAT aspects in connection with the disposal of a commercial property investment to a pension fund for consideration of £135m, including working with the purchaser’s advisers in preparing joint instructions to leading Tax Counsel
- advising on the tax aspects of the disposal of a company specialising in the provision of information, news and research in global base and premium metal markets for consideration of approximately £15m, including advising on the PAYE and NIC issues in connection with the exercise of share options in conjunction with the sale
- advising on the de‑enveloping of high-value residential properties
- advising a major US insurance company on the UK tax implications of its proposed investment in an English limited partnership fund