Restructuring Tax Services
Our tax team is experienced in working with businesses of all sizes, from privately-owned SMEs to listed multinationals, and across a wide range of industry sectors to structure and put in place pragmatic and tax efficient reorganisations, restructurings and refinancings.
We can support you with:
Early options / accelerated M&A
- Advising on the tax implications of alternative restructuring options
- Tax advice on selling a business via an insolvency process
- Structuring transactions to maximise tax efficiency, (managing transaction tax costs and tax efficiency of the ongoing business model)
- Preserving tax attributes
Financial restructuring
- Supporting borrowers, lenders and other stakeholders in reviewing tax planning and identifying actual and contingent tax liabilities
- Structuring transactions and developing tax steps plans to maximise tax efficiency, for instance, debt modifications or releases, debt-for-equity swaps and intragroup debt restructurings and capital reductions
- Helping to develop a tax-efficient post transaction capital structure
- Preserving tax attributes following changes to the capital structure
Cash tax liquidity and operational restructuring
- Reviewing tax cash-flow forecast assumptions and tax sensitivities
- Tax forecast modelling
- Reviewing and identifying group tax efficiency improvements
- Indirect taxes / VAT & Customs taxes optimisation including any ongoing support
- Support with HMRC stakeholder conversations including the approach to ‘time to pay’ applications and other potential tax deferral requests
Corporate simplification and legal entity rationalisations
- Identifying and preserving tax attributes
- Preparing tax steps plans and managing any tax risks from simplification and reorganisation steps
- Tax-efficient repatriation of cash / value to shareholders
Tax structuring on reorganisations
- Advising on the tax implications of legal structure changes
- Tax-efficient structuring of legal entity reductions and group rationalisations
- Tax-efficient structuring of group mergers, de-mergers, hive down and hive across of trade and assets and joint venture investments
- Advising on repatriations of value to shareholders and managing shareholder succession planning and reorganisations of shareholdings
Financing transactions
- Cash tax modelling support, including tax P&L modelling
- Advising on the structuring of new financing including on the tax impact of bespoke terms and the structural and geographical location of borrowings
- Assessing the key tax impact of new borrowings, including the tax deductibility of finance costs, the tax impact of hedging arrangement and any withholding tax costs
- Post-transaction compliance
