Company Tax planning
Company
Reorganisation
Company A Limited owned an asset worth a substantial amount. The asset was in a company in which the owners were involved in entrepreneurial ventures. The directors were looking to continue with their speculative business ventures yet wanted to protect the asset from the commercial risk.
Comment: Shipleys Tax undertook a group reconstruction which resulted in the asset being transferred to another entity without any immediate tax liability to the company or its shareholders.
Partial Sale
Company X Group Limited was looking to sell off two subsidiaries to a buyer in exchange for shares. With the structure the client had in place, the sale of the two companies would have resulted in a tax liability of around £1.8 million on a paper gain and also caused the shareholders to lose favoured tax status.
Comment: Shipleys devised a group reorganisation which resulted in the two companies being sold with no immediate tax liability to the group or its shareholders.
Share schemes
Company Y Limited wished to reward and tie in employees. Bonus schemes were expensive and arbitrary and caused cash constraints.
Comment: Shipleys implemented a tax efficient share scheme arrangement. This achieved the client’s objectives and also gave the founder shareholders the opportunity to establish an alternative exit strategy.
Parallel companies
Company A Limited had a very complex company structure comprising of a number of non-trading intermediate holding and parallel companies which served no particular purpose and was not a tax efficient structure. The structure had arisen as a result of a piecemeal acquisitions and shareholder changes which was administratively difficult to manage. The parallel companies were related and had numerous inter company loans which the directors wanted to make tax efficient.
Comment: Shipleys implemented a tax efficient group reorganisation and put measures into place which would enable them to take full control of their inter company loans with minimal tax consequences.
Latest news & blogs…
HMRC backtracks on APN’s
HMRC has backtracked on hundreds of Accelerated Payment Notices (APN) after admitting defeat following an application for Judicial Review. This affects the notices it has issued to hundreds of taxpayers as a result of a Judicial Review lodged on their behalf. This is not the first time that HMRC has undertaken a withdrawal of APNs that they had previously issued.
APNs were challenged on a number of grounds including the argument that the Employee Benefit Trust arrangements under consideration were not ‘notifiable’ to HMRC, under the DOTAS regime. HMRC has now admitted that it did not have the right to issue the APNs in relation to these arrangements.
Shipleys Tax Planning partner, Shabeer Yousuf CTA, says “this case demonstrates, that a taxpayer in receipt of an APN should not automatically assume that HMRC has followed the correct processes and exercised its powers lawfully, the taxpayer should seek specialist advice.”
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