Bespoke advice for the questions where the most is at stake.

Tax is at its most valuable when it is considered early. We advise on the sale and purchase of companies, property and other assets; the efficient extraction of profits and gains; and the design of holding structures fit for today and the next generation. Where a transaction has already taken place, we provide post-transaction opinions, whether for additional assurance or because HMRC has shown an interest.

• Acquisitions and disposals of companies, businesses and assets
• Tax-efficient profit and gains extraction
• Asset-holding and ownership structures
• Succession and estate planning
• Group reorganisations and HMRC clearances
• Asset protection and offshore holding structures
• Post-transaction review and opinions

Property is taxed at almost every stage, and the rules grow steadily more hostile to the unwary. Whether you are incorporating a portfolio, planning a development, restructuring holdings or dealing with an offshore element, we advise on the full stack of property taxes and how they interact.

• Stamp Duty Land Tax on complex transactions
• Capital gains and corporation tax on disposals
• The taxation of property development and trading
• Incorporation and restructuring of portfolios
• ATED, non-resident landlords and non-resident CGT
• VAT on land and buildings

Trusts remain one of the most effective tools for holding and passing on wealth, but they carry a demanding tax and compliance burden and are increasingly the subject of dispute. Our work frequently has both a UK and offshore element, and we assist offshore trustees to achieve efficient outcomes consistent with their duties.

• Creation and structuring of UK and offshore trusts
• The relevant property regime and ten-year and exit charges
• Excluded property and the residence-based regime
• Restructuring, variation and appointments out
• Advising offshore trustees on UK tax exposure
• Employee ownership trusts and employee benefit trusts
• Trustee duties and beneficiary disputes

Where a person, trust or company is resident determines how much of their worldwide income and gains the UK can tax, and the rules for internationally mobile individuals have been substantially reformed. We advise before arrival or departure, and when a position needs to be defended.

• The statutory residence test and record-keeping
• Domicile of origin, choice and dependency
• Planning around the reformed non-dom regime
• Treaty residence and double tax treaties
• Pre-arrival and pre-departure planning
• Residence of trusts and companies
• Permanent establishment analysis for cross-border activity

An HMRC enquiry is disruptive, expensive and stressful, and the outcome often turns on how it is handled from the outset. We advise and assist across the range of civil enquiries and investigations, and can give protective advice before any approach is made. As advice from a solicitor, our analysis can attract legal professional privilege.

• Civil investigations, including COP8 and COP9 / CDF
• Voluntary disclosures and settlements
• Discovery assessments and information notices
• Penalty mitigation and suspension
• Alternative dispute resolution with HMRC
• Support through tax litigation, working closely with SRA authorised firms and specialist counsel
• Pre-transaction and pre-enquiry protective advice