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