Case Studies

A mid-market business had agreed terms with a private equity house, but its existing group structure would have triggered a substantial tax charge on completion. The deal was at risk of collapsing — or the shareholders absorbing a seven-figure tax bill — unless a solution was found quickly.

We were brought in by the instructing law firm at short notice. Working under tight transaction timelines, we designed a multi-step restructuring plan that sequenced the corporate steps carefully to utilise available statutory reliefs without disrupting the commercial deal. We worked directly with legal counsel and the PE advisers throughout.

The reorganisation completed on time and without disruption to the deal process. The PE investment proceeded as planned and the shareholders avoided an estimated £1.8M in tax that would otherwise have crystallised on completion.

A US technology group was expanding into the UK and Europe. The structure proposed by their US advisers would have created unnecessary UK permanent establishment exposure and double taxation on profits — a significant and avoidable drag on the business from day one.

We advised on the optimal UK entry point, treaty positioning and the inter-company arrangements needed to ring-fence UK exposure. Working alongside the client's US counsel, we coordinated the cross-border approach so that nothing fell through the gap between jurisdictions.

The business launched its UK and European operations on a clean, tax-efficient footing. The revised structure generated an estimated £450K annual saving against the original proposal and materially reduced the group's ongoing compliance risk.

A founder-led business was in advanced sale negotiations. The founder's shareholding had evolved over the years and, as structured, Business Asset Disposal Relief was only partially available — meaning a significant portion of the proceeds would have been taxed at the full CGT rate. No pre-sale planning had been done.

We undertook an urgent review of the shareholding structure and the sale timeline. We implemented a pre-sale reorganisation — including share class arrangements and careful sequencing around the exchange date — to maximise relief eligibility without jeopardising the buyer's process or the deal timetable.

The shareholders retained an additional £1.2M in after-tax proceeds compared to proceeding without advice. The transaction completed on schedule and the buyer was entirely unaffected by the restructuring steps.

A family business owner came to us with a projected IHT liability of over £3M. The estate was complex — a mix of trading business assets, investment properties and a sizeable investment portfolio. Business Property Relief was only partially available, and no planning had been put in place. The client wanted to protect the business and preserve wealth for the next generation without losing control.

We carried out a comprehensive estate review and identified the restructuring needed to separate trading and investment activities — a critical step to unlock full BPR eligibility. We then advised on a phased programme combining lifetime gifting, the establishment of a family investment company and trust arrangements, each step carefully designed to manage HMRC risk.

The client's IHT exposure was reduced by an estimated £2.1M. The business remained under full family control throughout and the planning was implemented over two years to maximise reliefs without triggering challenge.

A business owner received an HMRC enquiry spanning several years of personal and business returns. The enquiry letter raised a series of technical challenges and threatened significant additional assessments. The client's existing advisers were struggling to manage the process and HMRC's tone was becoming increasingly assertive.

We took over conduct of the enquiry entirely. We reviewed the full correspondence history and underlying documents, identified where HMRC's technical analysis was flawed, and rebuilt the response strategy from scratch — engaging directly with the Inspector with clear, confident arguments backed by detailed technical analysis.

The enquiry was closed with no additional tax liability. The client avoided significant penalties and interest, and the matter was resolved without the need for a formal appeal or tribunal — saving further cost and uncertainty.