We advise a wide range of clients including banks, funds and other financial institutions, insurance companies, real estate developers and investors, retailers and public bodies. Example clients include Canary Wharf Group, Credit Suisse, Royal Bank of Scotland and Tesco Plc.
Below are some areas of Tax Consultancy and Structuring that we specialise in.
Challenging market conditions and economic uncertainty caused by the financial crisis, considerably alter the corporate tax landscape, with the rate and complexity of change on the rise. Corporate organisations, particularly those contracting with the UK Government, are facing increased scrutiny from HMRC which, like tax authorities around the world, is seeking to maximise its tax revenue and protect its tax base from challenges. Public interest in the tax affairs of large multinationals has also intensified, with tax-related stories rarely out of the headlines in mainstream media.
We help our clients structure their tax affairs to complement their business strategies and maximise tax efficiencies, working closely with the firm’s other specialist groups to provide an integrated transactional experience. We also advise on all aspects of corporate M&A and demergers, group restructurings, complex joint ventures, and any issues posed by outsourcing and cost-sharing.
Our tax lawyers act for a wide range of clients including joint venture parties, multinationals, domestic (and international) corporates, privately held corporate groups and companies restructuring their debt burden.
Our work in this area includes:
Since the financial crisis, regulators have placed a number of measures on some banks to ensure they do not overextend themselves with excessive lending. This has led to a decline in lending levels amid a faltering economic recovery, as non-traditional lenders try to step in and fill the gap. Alongside this tax authorities world-wide have become increasingly aggressive, challenging a number of tax structured investments.
We advise on the full range of financing transactions such as structuring distressed debt in a tax efficient manner, sophisticated asset finance structures, securitisations and structuring new credit providers.
Our tax lawyers act for a wide range of clients including major banks and borrowers, funds, other financial institutions, intermediaries and corporates, both in the UK and globally. Working alongside our UK team, we also have tax lawyers based in our Moscow, Frankfurt, Abu Dhabi and Singapore offices, who help serve clients in these regions and beyond.
Our work, both within the UK and across multiple jurisdictions, includes:
Our investment management group comprises lawyers specialising in corporate, regulatory, taxation and finance law. We are recognised as a market leader in structuring indirect real estate and private equity investments, acting for several of the most active fund structurers. We regularly advise on the most appropriate vehicles (onshore and offshore) to use for fund and joint venture structures, including the structuring of appropriate feeder funds for different classes of investors.
Our work in this area ranges from advising on the establishment of the structure, to assisting with fund restructuring, and transitional changes and exit strategies, both on behalf of the fund and individual investors. We also have extensive experience of advising on the structuring and establishment of private collective investment structures for ultra high net worth international families.
We regularly develop investment products for international private banks and financial institutions aimed at particular investor markets. We also advise individual investors and have considerable expertise in advising on the tax situs, source and personal tax consequences for investors (both remittance basis and non-remittance basis users) of a broad range of investments - including bonds, hedge funds, structured products, money market instruments, life bonds and other insurance products, OEICs and excluded indexed securities.
In an area where tax efficiency is key, our tax & private client team assists on all tax aspects of a broad range of funds. We also give commercial and practical advice to fund managers on carry/promote planning. The team works closely with our overseas offices and extensive preferred firm network on complex international fund structures to give a global tax reach. The team participates in industry groups and Treasury/HMRC consultation processes in relation to REITs, PAIFs and investment funds generally.
Our work includes:
Advised a large investment bank as financier on the high profile funding of a £900m non-performing commercial real estate portfolio being sold by a major clearing bank. The transaction involved advising on due diligence of a portfolio of complex non-performing commercial real estate loans, the structuring of the acquisition vehicle and the financing by the investment bank of the acquisition of the portfolio and the subsequent securitisation exit.
Advising on the development of a data centre situated on Holford Industrial Estate to the north of Birmingham city centre.
Advising an international financial institution on a partnership structure to enable individual private clients to invest in a range of bespoke structured products in a tax efficient manner.
Advised the South Korean sovereign wealth fund on the tax aspects of the share purchase from HSBC of an SPV owner of the HSBC tower at 8 Canada Square and on associated asset management arrangements with JP Morgan Asset Management.