Restructuring tax support for Intermediaries

Our Restructuring Tax Team recognises the importance of considering tax throughout a project to help ensure that the relevant tax risks and opportunities are highlighted in a timely manner to allow commercial decisions to be made and issues to be addressed prior to implementation.

Tax issues that may arise for a company looking to restructure are numerous, wide-ranging, of varying levels of complexity and will be dependent upon the type of restructuring being undertaken.

Therefore, engaging tax specialists at the earliest possible stage of contemplating any form of restructure / reorganisation will help to avoid a multitude of potential tax pitfalls.

Why is tax important in restructuring

Generally, if there’s a change, there is likely to be a tax consequence. Knowing that tax consequence, being able to mitigate the tax impact and/or budget for the potential cost can all assist in delivering a commercially successful restructure.

Tax should be considered from the offset / as early as strategically possible, as it can be extremely difficult to preserve a tax benefit or mitigate a tax liability in an efficient manner post-completion.

Our team recognises the importance of considering the potential tax implications of a restructure, to ensure that tax attributes and tax risks are assessed from the offset and factored into planning to avoid any nasty surprises further down the line.

Our early involvement provides relevant stakeholders with time to understand the key tax issues and make informed decisions.

How we can help

Our specialist restructuring tax team provides support to ensure that tax is considered throughout a project, with relevant tax risks and/or opportunities highlighted in a timely manner to ensure that they can be addressed prior to implementation.

We can assist in a number of different areas

Internal reorganisations	Hive-ups Hive-downs Trade transfers Trade consolidations
Group reorganisations	Group rationalisations Managed wind downs and dissolutions Intra-group sales (UK or Global group) Planning to remove dividend blocks Efficient group structure/group consolidations
Balance sheet restructuring	Debt restructuring and re-financing
Pre-sale structuring	De-mergers Carve-outs Restructuring to obtain efficient sale structure