Areas of Practice

Tax Strategy for International Groups

Tax-efficient structures for complex cross-border corporate transactions, including intermediate holding and finance companies, the exploitation of intellectual property, double tax agreements and transfer pricing. We believe it is important to include the tax adviser in the discussions at an early stage of good pre-transaction planning. This often reveals useful savings which may impact on commercial strategy. We can also help in analysing the tax problems of the other party, as this sometimes suggests good negotiating strategy.

We have been through several economic cycles. During the "bull" phase the emphasis is on deals, acquisitions, mergers and joint-ventures but, in times like the present, we can help clients to save money by assisting in tax housekeeping and restructuring their operations and activities. Our clients are often surprised at how much can be achieved by a series of simple but well-conceived and coordinated steps. As a closely-knit team, we can be very cost-effective.

We like working closely with in-house tax teams and have successfully worked on a number of major projects where we have been brought in to support them in taking a broad overview of strategic issues covering different aspects of the issue in more than one country.

The typical in-house team may only deal with a major merger or reconstruction once in their career, while we have had a broad and varied experience of providing this service for large multi-national companies. This complements the skills of the team, with their deep understanding of the working of the company and the inevitable non-tax constraints on a solution.

ITSG

We are members of the International Tax Specialist Group (www.itsgnetwork.com) comprising similar small high level firms of tax professionals in other countries. Through this and other connections, we can bring together a first class team of specialists in different countries. We can work with any existing advisers to clients, or with the most appropriate professional in a country regardless of affiliation.

Advice for companies investing into Europe, including Eastern Europe

We can give a 'one stop' overview of effective tax rates and incentives for high-tech, financial service and other companies contemplating expansion into Europe. As part of a pre-planning strategy this is a cost-effective way of getting an overall picture. The client will then be able to decide which countries to eliminate and therefore avoid undertaking a detailed analysis of the many non-tax factors of all potential countries. Our procedures allow us to consult informally with overseas correspondents where necessary without them having to undertake an extensive due diligence on the client. We then only need to do a detailed report signed off by everyone involved when there is a more precise program or a small number of alternatives on the table.

Financial Instruments

We have extensive experience in the international tax treatment of foreign exchange, multi-currency financing and derivatives. In advising our clients on the use of cross-border financial instruments we use a systematic approach, comparing the laws of several countries which then results in tailored solutions. This is often much better than the standard "products" often sold in the market.

International Taxation of Executives

Compensation packages for internationally mobile executives and others, including the use of retainer payments, options and pension rights.

Entrepreneurs and other High-Income Earners

Tax planning for entrepreneurs and for authors, inventors, entertainers, sportsmen and consultants and others who may be regarded as self-employed, having an income from several countries.

Trusts and Family Investments

We have a wide range of clients, with some emphasis on financial markets and structures, but many are business families with individuals, companies and trusts in more than one country who prefer our integrated approach to having to deal with separate departments of large firms for themselves, their companies and their trusts.

Tax-planning for family and other private wealth held in a single country or in many different countries around the world. We are active members of the Society of Trust and Estate Practitioners (STEP) and Michael Cadesky, co-founder of ITSG, is a recent past international chairman.

Investment Funds

Tax and regulation planning for offshore investment, hedge and private equity funds. We have close links with service providers we can bring into the project. In our advice we pay particular attention to the investor profile and the various asset classes to ensure efficient tax planning. By minimising tax leakage we believe we can make a positive contribution to the internal rate of return.

Services to Smaller Companies

Advice for companies in the early stages of expanding abroad and for high-technology start-ups. In this, we work closely with London Strategy Group headed by John Precious, former finance director of Wellcome and managed from our office which provides a range of services to early stage, mainly high-technology, companies.

Tax Compliance Work

We also provide a tax compliance service, completing UK tax returns for companies, individuals and trusts.

VAT and other Indirect Taxes

Planning for businesses involved in international trading of goods and services.