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Our Corporate Tax team provides clients with expert and commercially sound advice on finance, insolvency and funds tax, encompassing all types of financing arrangements, insolvency matters and investment funds.
Our expertise includes bank lending, debt capital markets, project finance, real estate and infrastructure finance, asset finance and securitisations. Key tax issues addressed include interest deductibility, withholding taxes, application of tax treaties, anti-hybrid rules, bank levy, VAT, stamp taxes and other indirect taxes.
As part of the wider Corporate Restructuring and Insolvency team, we advise clients on the tax implications of corporate and financial restructurings, distressed transactions (including investments, acquisitions and sales) and the full range of insolvency procedures. These include administrations, receiverships, liquidations and company voluntary arrangements.
We have considerable experience of advising on the taxation of investment funds, investors and fund managers, covering all stages of the fund life cycle from formation through to exit, including fund structuring and restructuring, financing, investments and redemptions.
We advise on authorised funds (including authorised unit trusts, open-ended investment companies and authorised contractual schemes) and unauthorised funds (including limited partnerships, offshore trusts and offshore companies), both UK and non-UK domiciled.
Advising on and negotiating the tax provisions of facility agreements, hedging documents and other financing documents, including LMA and ISDA-based documentation.
Advising on the tax position of parties to financing arrangements (including Shariah-compliant finance), the tax deductibility of interest payments, and tax treatments across several other significant finance related areas.
Advising on the application of withholding taxes in the context of international finance arrangements, availability of exemptions and reliefs, necessary procedural formalities, and tax gross-up provisions in documentation.
Providing transactional tax support for administration sales and insolvency proceedings, and providing tax advice to administrators and distressed companies.
Advising on the tax treatment of restructuring distressed debt, including debt write-offs, debt releases, debt/equity swaps and debt modifications.
Advising on tax considerations relevant to the structuring of a new fund and providing tax input in fund documentation, and the tax treatment of investments in UK or non-UK funds for investors, including pension schemes.
Advising on tax considerations relevant to funds and fund managers, including treatment of carried interest, application of disguised investment management fee rules etc., VAT treatment of services and stamp tax treatment of investments.
Key Contact
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Thought leadership
11 March 2025
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Thought leadership
6 March 2025
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Legal updates
24 May 2024
