Restructuring Tax Services

Efficiently structuring working capital and debt adjustments to preserve tax attributes and limit tax risks.

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