The Tax Knowledge Centre by ETC Tax – Specialist Tax Advice & Financial Tax Related Matters – All the info you could need in one place…
Highly commercial corporate tax advice to support your business and personal objectives.
But the tax landscape has never looked more complex. Regulations are constantly changing, and tax authorities across the globe are typically rigorous in their enforcement. Businesses have to keep pace.
At every stage in the business lifecycle, effective corporate tax advice plays an instrumental role in helping companies to meet their commercial objectives, which could be expanding internationally, preparing for a sale or rationalising operations.
As specialist tax consultants, we work with individuals, entrepreneurs and businesses to help them achieve their personal and commercial objectives in a tax efficient manner.
How you structure assets and maximise relief opportunities can impact your financial performance and competitive position.
From the outset, we work to understand your wider commercial goals. These goals will drive the agenda for corporate tax planning, as we help you achieve your objectives while optimising tax relief and ensuring legislative compliance across all jurisdictions relevant to your operations and circumstances.
Clearly, where a business is looking to expand outside of the UK, then tax issues and opportunities are likely to arise. We can assist in this process.
International real estate tax
We have recently advised on a number of large scale property developments, including creating an investment structure for a US hotel complex looking to raise capital and targeting UK resident investors. We have also been involved in the process of setting up a Real Estate Investment Trust (“REIT”), which is to be listed on the Channel Islands Stock Exchange.
Internationally mobile workers
Business is now a global affair and, as such, companies which operate cross border are likely to have members of staff spending time in different locations. This may create tax complications.
We have recently advised the London operation of one of the largest securities and derivatives brokers on the Moscow markets in a number of areas; including the tax treatment of short-term business visitors, non-resident directors and tax equalisation.
Intellectual property (“IP”) structuring
International groups may have the opportunity to structure how and where they hold their intellectual property, including goodwill. Recently, we advised an IP-rich international company looking to introduce their products in to the UK, Europe and the US on a suitable holding structure to exploit their know how efficiently.
We have provided tax advice in relation to the innovative use of UK SIPP’s and SSAS’s to fund commercial ventures.
We are also leading experts on the taxation of Qualifying Recognised Overseas Pension Schemes (“QROPS”) and Qualifying Non-UK Pension Schemes (“QNUPS”) and have advised many individuals and professional clients on the use and establishment of such structures.
UK SIPPs and SSASs
It is a misnomer that one cannot transact with one’s own pension scheme. We have provided tax advice in relation to UK pension schemes funding commercial ventures – such as property conversions and developments.
Pension Led Funding (“PLF”)
We have substantial experience in using pension schemes to fund existing trading businesses and investment businesses.
QROPS / QNUPS
QROPS and QNUPS are non-UK pension schemes but both benefit from varying degrees of recognition from HMRC.
The former can usually take transfers from UK registered pension schemes, without a tax charge.
The latter is a flexible structure for funds not currently in a pension scheme. It is particularly useful for UK situate property, and benefits from an IHT exemption in appropriate circumstances.
If you are a UK-based residential property investor then you will be conscious that there have been a number of significant changes over recent years.
These changes need to be factored in to your business model, and it may be desirable to review whether that business model is still appropriate. Furthermore, property is usually an asset class – whether residential or commercial – which is exposed to both IHT and CGT. We are leading the way in advising property investors and buy to let landlords on how to structure their portfolios.
Non-UK investors in UK residential property have probably suffered even more over the years at the legislator’s hand than those based in the UK. We have extensive experience in advising such investors.
Property development is a venture ‘in the nature of trade’, and, assuming other conditions are met, the property development activity will qualify for valuable reliefs, such as Entrepreneurs Relief (“ER”) for capital gains tax purposes and Business Property Relief (“BPR”) for IHT purposes.
It is common, for commercial purposes, for a property developer to operate each development through a separate SPV. This can also achieve attractive tax benefits. We can advise on how to approach this structure from a tax point of view, including the impact of the new anti-phoenixing rules which have been introduced by the Government.
We have extensive experience of advising both property investors and developers on all aspects of property specific taxes, such as SDLT, VAT and capital allowances.
Profit extraction, reward and incentive planning
At some point, an owner of a business will want to extract value from it as a reward for their efforts. This can be done in a number of ways, each with its own legal, economic and tax consequences.
It may also be appropriate to incentivise key staff and align their interests with those of the business. The Enterprise Management Incentive (“EMI”) scheme is a popular, Government-approved route to do this. Other non-approved routes might also be appropriate for your business. We can advise on all relevant options.
We are also a supporter and member of the Employee Ownership Association.
Succession planning and exit
Business owners will at a certain point want to start planning their exit from the business. This could entail passing on the business to the next generation, or selling to a third party – whether those owners are serial entrepreneurs, and will start all over again; or whether they want to retire and live out their days in a sunnier climate! We have extensive experience in advising across a wide variety of scenarios and circumstances.
Research and development (“R&D”) and other business reliefs
Tax relief for qualifying expenditure on R&D is incredibly attractive and certainly worth exploring.
It is worth pointing out that R&D relief is not simply available to businesses employing ‘armies’ of scientists in white coats. It is, in fact, available to any business, which seeks to improve any process; with successful claims having been made for software companies, food businesses and cosmetic dentists.
Many other business reliefs are available, for example, in respect of capital investment in plant and machinery (capital allowances).
We also regularly deal with reliefs, which are available for those investing in SME’s and start-ups, such as the Enterprise Investment Scheme (“EIS”) and Seed Enterprise Investment Scheme (“SEIS”) and have significant experience in this area.
We have extensive expertise in advising on a wide variety of VAT issues.
Many of the same issues will apply to start up and growth companies as apply to their more established SME counterparts; however there may be an increased focus on tax reliefs such as EIS and SEIS for investors.
Other reliefs such as Investors Relief and Business Investment Relief may also be relevant.
Again, R&D may be in point. If the business is at present loss-making then a successful claim may result in a payment from HMRC.
Furthermore, whilst the business is in an early stage, it is more important than ever for the well-advised entrepreneur to spend some time properly considering the structure of the business, such that it is as tax efficient as possible, in meeting personal and commercial objectives.
We can provide full advice and implementation in respect of individuals looking to set up charitable trusts and foundations to pursue their philanthropic aims.
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