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Reorganisations and restructuring

Helping you navigate the tax aspects of your
reorganisation or restructuring. 

Corporate restructuring and reorganisations give rise to a range of tax issues which will require careful consideration and planning. We can ensure that any reorganisation, restructuring or diversification of your business is undertaken in a tax efficient manner.

Whilst involving some upfront cost, a reorganisation to achieve the right structure, can often lead to significant savings and create opportunities for a business to grow and innovate in the medium to longer term.

There are a number of tax reliefs available which can minimise or eliminate tax charges arising as a consequence of a reorganisation. Many of these reliefs have specific rules and conditions attached to them. We can help you navigate your way through a restructuring, reorganisation, merger or demerger to ensure that it is conducted in the most tax efficient way possible. Getting it wrong can led to unexpected surprises and tax costs.

With diversification comes opportunity and risk. Our corporate finance and tax teams work closely together to ensure any such ventures are structured to enable the maximum benefit to accrue to the business.

Our co-ordinated, cross disciplined restructuring approach will ensure specialist advice is sought across a range of taxes including corporation tax, vat, employment taxes and stamp taxes.

We can help you:

  • Work out your strategy, supporting you now and helping you plan where you want to be in the future.
  • Decide the right structure for your business, ensuring that it is fit for purpose, delivers on your objectives and is tax efficient.
  • Understand the pros and cons of the different restructuring routes to achieve your desired structure.
  • Demerge and reorganise parts of your business for future sale or expansion.
  • Map out the transaction steps you need to take to move your business from it is ‘now’ to the ‘new’ proposed structure.
  • Ensure that valuable assets and reliefs are appropriately considered and protected, including: properties, the utilisation of any tax losses, capital allowances, R&D tax reliefs and enterprise management incentive (EMI) schemes.
  • Apply for advance tax clearances from HMRC, providing you with some certainty that the restructuring will be accepted by HMRC and the tax reliefs will apply.
  • Structure tax efficient share incentive plans to reward and incentivise management.
  • Ensure a smooth reorganisation, with close collaborating with your lawyers as required.
  • Deal with post transaction tax investigations and disputes.
Hive up checklist [pdf]

Hive up checklist

Checklist of administrative matters to be considered on a transfer of trade and assets.

Download our checklist [pdf]


We look at group organisations and demergers and how to find the right structure for your company.

Contact us

Simon Crookston
Simon Crookston
Partner, Corporate Tax