Reorganisations & Tax-Efficient Structuring

Reorganisations & Tax-Efficient Structuring

Why reorganise your existing group structure?

To increase administrative, operational or economic efficiencies – updating a group structure can reduce intra group administration, consolidate certain operations within a single entity, and clarify management responsibilities.

To raise finance or improve supplier term – having a well-structured group is associated with higher credit ratings, making it easier to raise finance and increase credit limits with suppliers to improve cash flow.

As a lead-up to an acquisition or sale of a company or business – before buying a business you may need to create a new subsidiary in the group to hold it. As a vendor, a pre-sale reorganisation can make your proposition more attractive to buyers.

Following an acquisition of a company or business – this helps ensure that the acquired company or assets are integrated into the existing company structure in the most effective way.

To de-risk or strengthen your group – through demerging part of the group, undertaking debt/equity swaps, reviewing intercompany accounts and trading or simply ‘tidying up’ the group structure.

To reduce tax liability by creating a more tax efficient group structure – group reorganisations for tax purposes may include property or asset transfers, rearranging cash flows, consolidating subsidiaries or creating new companies. Reorganisation may be particularly tax efficient for multinational groups.

The H&K Approach – how we help?

Reorganisations can be implemented by way of a transfer of shares or a transfer of the business or assets. We help you choose the best option taking into account crucial considerations such as liability, complexity, and consent issues.

Taxes arise when the shares or assets are disposed of as part of a reorganisation. Depending on what you are disposing of, stamp duty, stamp duty land tax (SDLT), stamp duty reserve tax (SDRT), VAT, corporation tax, or capital gains tax (CGT) may be due. Reliefs on these taxes are available on transfers made between UK group companies. We will help you structure your reorganisation in a way that takes maximum advantage of these reliefs and minimises your tax liability.

Our expertise enables us to help you choose the structure that brings maximum benefit in the most tax efficient manner. We ensure your compliance and accurate reporting while safeguarding and working towards increasing your business’ value.

Get in touch with our Team to find out how your business can benefit from our group structuring and reorganisations service.
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