MODERN APPROACH TO
TAX
Tax law supports the way businesses, individuals and investors structure transactions, manage liabilities and respond to HMRC, helping them make informed decisions while meeting their legal obligations.
HOW WE CAN HELP
strategic tax advice for businesses and individuals
Tax considerations can affect commercial transactions, business structures, property investments, remuneration arrangements and succession planning. Our Tax lawyers provide clear legal advice to help clients understand their position, manage risk and structure their affairs in a commercially and personally appropriate way.
We advise businesses, shareholders, investors, property owners and private individuals on the legal aspects of UK taxation. This includes transactional tax, corporate structuring, property taxes, employment-related tax issues, inheritance tax planning and disputes or enquiries involving HMRC.
Our role is distinct from that of an accountant or tax-return preparer. Where calculations, valuations, filings or specialist accountancy input are required, your lead lawyer can work alongside your existing accountants, tax advisers and other professional advisers.
Where a matter involves related areas such as Corporate, Commercial Real Estate, Employment, Private Client, Banking and Finance or Disputes, we can coordinate the appropriate expertise from across the Kingsley Wood community.
Who we advise
- Businesses and corporate groups
- Founders, directors and shareholders
- Investors and family offices
- Property owners and developers
- Employers and senior executives
- Entrepreneurs and business owners
- High-net-worth individuals and families
- UK and international clients
Discuss your Tax matter...
Speak directly with an experienced Kingsley Wood lawyer about your transaction, structure, HMRC issue or personal tax-planning requirements.
Corporate Tax
We advise companies, shareholders and corporate groups on the legal tax considerations arising from business operations, transactions and structural changes.
Our experience includes:
- Corporate acquisitions and disposals
- Business sales
- Corporate reorganisations
- Group structures
- Share-for-share exchanges
- Capital reductions
- Share buybacks
- Demergers
- Distribution and dividend arrangements
- Company reconstructions
- Corporate residence considerations
- Tax provisions in transaction documents
- Warranties and indemnities
- Coordination with accountants and tax advisers
We work alongside our Corporate lawyers to ensure that the legal and tax aspects of a transaction are considered together.
Transactional Tax
Tax can materially affect the structure, value and commercial outcome of a transaction.
We advise on the tax-related legal aspects of:
- Share purchases and sales
- Asset and business transactions
- Mergers and acquisitions
- Investment rounds
- Joint ventures
- Management buyouts and buy-ins
- Private equity transactions
- Corporate reorganisations
- Property acquisitions and disposals
- Refinancing arrangements
- Transaction documentation
- Tax covenants
- Tax warranties and indemnities
- Post-completion arrangements
Early advice can help identify material liabilities and ensure that the transaction documents allocate tax risk appropriately.
Business Structuring and Reorganisations
The legal structure of a business can affect ownership, governance, investment, succession and taxation.
We advise on:
- Establishing holding companies
- Creating group structures
- Incorporating new subsidiaries
- Business transfers
- Share-for-share exchanges
- Intra-group arrangements
- Corporate simplification
- Pre-sale reorganisations
- Post-acquisition integration
- Succession structures
- Partnership and LLP structures
- Joint ventures
- Investment structures
- Restructuring ownership arrangements
We coordinate with accountants and specialist tax advisers where detailed calculations, clearances or valuations are required.
Income Tax
We advise individuals, shareholders, business owners and executives on the legal issues arising from UK income tax.
Our experience includes:
- Tax treatment of contractual payments
- Shareholder and director remuneration
- Dividend arrangements
- Employment termination payments
- Consultancy and self-employment arrangements
- Partnership income
- Property income considerations
- Settlement agreements
- Deferred and contingent payments
- Cross-border income issues
- HMRC enquiries
- Tax-related contractual disputes
- Coordination with accountants on filings and calculations
We do not ordinarily prepare personal tax returns but can advise on the underlying legal issues and work alongside your accountant.
Employment Tax and Remuneration
Employment arrangements can create tax consequences for employers, employees, directors and consultants.
We advise on:
- Employment status
- Employee and consultant arrangements
- Salary and bonus structures
- Benefits and incentives
- Termination payments
- Payments in lieu of notice
- Settlement agreements
- Share-based remuneration
- Employee ownership arrangements
- Director remuneration
- Off-payroll working considerations
- Employment-related securities
- Tax indemnities
- Coordination with Employment and Corporate lawyers
Our advice focuses on ensuring that the legal documents properly reflect the intended arrangements and allocate responsibility clearly.
Property Tax
Property transactions can involve several forms of taxation and should be considered carefully at an early stage.
We advise on the legal aspects of:
- Stamp Duty Land Tax
- Commercial property acquisitions
- Property disposals
- Property investment structures
- Development transactions
- Property joint ventures
- Corporate acquisitions involving property
- Transfers between connected parties
- Intra-group property arrangements
- Capital gains considerations
- VAT on property transactions
- Lease premiums and incentives
- Property ownership structures
- Tax provisions in property documents
We work with our Commercial Real Estate lawyers and the client’s tax advisers to coordinate the transaction.
VAT, Customs and Excise
VAT, customs and excise issues can affect pricing, contractual responsibility, supply chains and cross-border trade.
We advise on:
- VAT provisions in commercial contracts
- VAT treatment of transactions
- VAT on property
- Business transfers
- Contractual allocation of VAT liability
- Import and export arrangements
- Customs obligations
- Cross-border supply arrangements
- Excise-related contractual issues
- Supply-chain responsibilities
- HMRC correspondence and enquiries
- Disputes concerning VAT treatment
- Recovery of tax under contractual provisions
- Coordination with accountants and customs advisers
The detailed tax treatment will depend on the transaction and should be confirmed with the appropriate specialist advisers where necessary.
Inheritance Tax and Succession Planning
Inheritance tax can form an important part of estate, succession and family-wealth planning.
We advise individuals and families on:
- Inheritance tax planning
- Lifetime gifting
- Wills and estate planning
- Business succession
- Family investment structures
- Trust arrangements
- Property ownership
- Business and agricultural interests
- Estate administration
- Tax-related provisions in wills
- Passing business interests to the next generation
- Family governance
- Coordination with accountants and financial advisers
- HMRC issues arising during estate administration
Our Tax and Private Client lawyers can work together to ensure that succession arrangements reflect both personal wishes and the wider legal position.
Capital Gains Tax
Capital gains tax may arise when individuals, trustees or businesses dispose of property, investments or other assets.
We advise on the legal issues connected with:
- Business disposals
- Share sales
- Property disposals
- Transfers between family members
- Trust and estate transactions
- Corporate reorganisations
- Deferred consideration
- Earn-outs
- Share exchanges
- Partnership interests
- Separation of business assets
- Contractual allocation of tax liability
- Tax warranties and indemnities
- Coordination with accountants on calculations and reporting
HMRC Enquiries and Tax Disputes
HMRC enquiries and disputes require careful analysis of the underlying facts, documents and legal position.
We advise on:
- HMRC information requests
- Tax enquiries
- Assessments and determinations
- Contractual tax disputes
- Tax-related investigations
- Disputed transaction treatment
- Penalty issues
- Settlement discussions
- Internal reviews
- Appeals
- Alternative dispute resolution with HMRC
- Tribunal proceedings
- Document and evidence management
- Coordination with accountants, tax advisers and counsel
Early advice can help clients understand the issues, preserve relevant evidence and develop a proportionate response strategy.
International and Cross-Border Tax
Transactions and arrangements involving more than one jurisdiction can create complex legal and tax considerations.
We advise on the English-law aspects of:
- Cross-border business structures
- International acquisitions and disposals
- Overseas investment into the UK
- UK investment overseas
- International joint ventures
- Corporate residence issues
- Cross-border employment arrangements
- International property ownership
- Double-taxation considerations
- Withholding-tax provisions
- Governing law and contractual allocation
- Overseas succession issues
- Coordination with foreign lawyers and tax advisers
- Multi-jurisdictional transactions
Where overseas tax advice is required, we can coordinate with appropriate advisers in the relevant jurisdictions.
Tax Risk in Commercial Agreements
Commercial contracts and transaction documents should clearly address responsibility for tax.
We advise on:
- Tax warranties
- Tax indemnities
- Tax covenants
- Gross-up provisions
- Withholding-tax clauses
- VAT clauses
- Employment-tax indemnities
- Stamp-tax responsibility
- Tax-related price adjustments
- Historic tax liabilities
- Tax clearances and conditions
- Information and cooperation obligations
- Conduct of tax claims
- Survival and limitation provisions
Clear drafting can reduce uncertainty and help prevent later disputes over responsibility for tax liabilities.
OUR PEOPLE
the tax team
Our Tax lawyers combine technical legal expertise with a practical understanding of business transactions, property, investment and personal wealth planning.
Dr Philippa Broughton
Partner
FAQs
1. When should I involve Kingsley Wood in a transaction with tax implications?
It is usually best to involve us before the transaction structure or principal commercial terms are finalised.
Early involvement allows us to identify material tax risks, coordinate with your accountants and ensure that the legal documents reflect the intended tax treatment and allocation of responsibility.
2. Does Kingsley Wood prepare tax returns and financial calculations?
Our role is principally to provide legal advice on tax matters, transactions, structures, disputes and contractual provisions.
Where tax returns, detailed calculations, valuations or routine compliance work are required, we can work alongside your existing accountant or coordinate with an appropriate specialist adviser.
3. Can Kingsley Wood coordinate tax advice with the wider legal transaction?
Yes. Tax issues frequently arise in corporate transactions, property matters, financing arrangements, employment packages and succession planning.
Your lead lawyer can coordinate the relevant Tax, Corporate, Commercial Real Estate, Employment, Private Client and Banking expertise so that the legal workstreams are managed consistently.
4. Can Kingsley Wood help with an HMRC enquiry or tax dispute?
Yes. We can review the underlying legal position, correspondence and supporting documents, advise on the available options and help develop an appropriate response strategy.
We can also work alongside accountants, tax advisers and counsel where specialist evidence or representation is required.
5. Can Kingsley Wood advise on both business and personal tax matters?
Yes. We advise on the legal tax issues affecting companies, shareholders, investors, property owners, business owners and private individuals.
Where business and personal arrangements overlap, we can coordinate the appropriate Corporate, Tax and Private Client expertise.
INSIGHTS
practical tax thinking for
businesses and individuals
Explore guidance from our Tax lawyers on transactions, business structures,
property, succession planning and responding to HMRC.
TAX ENQUIRIES
speak to our tax team
Whether you are planning a transaction, restructuring a business, managing property or succession arrangements, or responding to HMRC, tell us how we can help.
Phone number
+44 (0) 20 3551 8042
Our address
69 Carter Lane, London, EC4V 5EQ.
