Service 04
Business restructuring
Owner managed businesses frequently require restructuring as they grow, as shareholders' circumstances change, or in preparation for a sale or succession. A structure that suited a business at one stage can become an obstacle at another, whether by complicating a sale, exposing shareholders to unnecessary tax, or making it difficult to separate competing interests, and the right reorganisation can resolve these issues while leaving the underlying business intact. We advise on the full range of restructuring transactions, obtaining HMRC clearance where available, and working closely with solicitors to ensure the legal and tax analysis is fully coordinated from the outset. This coordination matters, because a restructuring depends on the tax treatment and the legal steps fitting together precisely, and a gap between the two can undermine the intended outcome. Our aim is to deliver a structure that achieves your commercial objective, stands up to scrutiny, and provides certainty before the transaction proceeds.
What is included.
- Holding company insertions using section 135 share-for-share exchanges
- Demergers by capital reduction, liquidation or statutory route
- Hive-downs of trade or assets into new subsidiaries
- Business property relief structuring for IHT purposes
- Enterprise Management Incentive (EMI) scheme design and HMRC valuation requests
- Pre-sale reorganisation for a clean exit
- HMRC clearance applications under ss.138, 139 and 701 CTA
Who this is for.
OMBs planning a sale or succession; businesses with complex structures requiring simplification; shareholders seeking to equalise or separate their interests; companies preparing for an MBO or private equity investment.