Tax overview

Our Tax group advises clients across various industry sectors. The team works closely with specialists in our other groups to help our clients plan and structure acquisitions, disposals, joint ventures, mergers and restructuring. We act for a wide variety of clients, including listed UK corporates, offshore entities, life and pension funds and foreign government funds.

Areas of expertise include:

Corporate Tax

Our Corporate Tax team provides support for our Corporate group on deals including flotations and consequent instructions from newly listed companies. The team has strong links with tax specialists in other jurisdictions, both within our European alliance and a wider tax grouping which covers ten jurisdictions. As a result, we can offer you seamless pan-European service.

Real Estate Tax

Our team works on all aspects of taxation and property - from simple transactions to complex structures optimising clients' income, capital gains, stamp duty land tax positions and VAT. Michael Cant and Simon Rose are recognised as leading VAT experts by the legal directories. As well as supporting our colleagues in the Real Estate group, we also work closely with the firm's Funds and Indirect Real Estate team to establish and represent a wide variety of joint ventures and property funds.

Tax Dispute Resolution

Our Tax Litigation team is experienced in acting for major corporate clients with tax disputes involving HM Revenue & Customs. The disputes include both indirect and direct taxes before a number of different forums, including the High Court, Court of Appeal and European Court of Justice.

In addition the team also advises on claims between private parties involving tax issues, such as tax warranty claims under share purchase agreements. Such disputes are often best resolved through mediation, rather than formal court proceedings, and to this end we draw on our strength in alternative dispute resolution.

Our latest alerts, briefings & reports
  • Tax residence: HMRC gets tough  
The First Tier Tax Tribunal decision of Laerstate BV v HMRC is the latest instalment in the tax residence saga. It demonstrates the increased rigour that HMRC will apply and emphasises the detailed investigations they are prepared to undertake to determine residency. View full briefing
  • PAYE Real Time Information: what you need to know  
In July 2010, HM Revenue and Customs (HMRC) issued a consultation document proposing changes to the PAYE system in order to address concerns regarding the operational efficiency of the current system. Subsequently, HMRC sought views on proposals to require employers to submit PAYE information as part of the employee payment process. View full briefing
  • Executive remuneration: the Government and the ABI address continuing shareholder concerns  
It comes as no surprise that executive pay in the financial sector remained in the spotlight throughout 2011 and the early part of 2012. Early 2011 saw a revised version of the Financial Services Authority’s remuneration code come into force and agreement reached between the government and the UK’s largest banks on executive pay levels and disclosure (Project Merlin). View full briefing
  • Enterprise Management Incentives: it just gets better!  
A number of changes to the rules governing Enterprise Management Incentive (EMI) options were announced in the Chancellor’s 2012 Budget on 21 March 2012. View full briefing
  • Taxation of post-termination employee share and share option gains: changes ahead?   
Since 6 April 2011, certain termination payments made to employees after issue of their P45 have been subject to a new tax regime implemented by the Income Tax (PAYE) Regulations 2011. "Share-based payments" (including employee shares, share options and related gains) made after the issue of the employee's P45 were carved out of the new regime, but this is set to change. Under draft regulations recently published by HM Revenue and Customs (HMRC), with effect from 6 April 2012, employers will have to apply the new regime to all taxable termination payments which are not included in the employee's P45. This will include notional payments received on the post-termination exercise of share options and release of share awards.  View full briefing
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