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Reorganisation and Restructuring

Helping you navigate your way through a restructuring or reorganisation project to optimise tax efficiency and support your commercial aspirations. 

Corporate restructuring and reorganisations give rise to a range of tax issues which require careful consideration and planning. 


Any reorganisation, restructuring, or simplification of your company or wider corporate group can usually be done in a way that is tax-efficient.

Although it comes with some initial costs, reorganising to achieve the right structure can frequently result in significant savings and create opportunities for a business to further develop and innovate in the medium to long-term to better meet its commercial goals, or be more attractive for investment or future sale.

A number of tax reliefs are available that can reduce or completely remove tax charges arising from a reorganisation. Many of these reliefs are subject to particular conditions, guidelines and requirements. Getting it wrong can lead to unexpected surprises and tax costs, as well as being a drain on valuable management time.

With change comes opportunity and risk

To ensure that any such initiatives are structured in a way that provides the business and its owners with maximum value and tax efficiency, our corporate finance and tax teams collaborate closely.

A variety of taxes, including corporation tax, VAT, employment taxes, and stamp taxes, will require consideration. Our cross-disciplinary team will consider all areas of taxation as part of our restructuring approach. Our accounting teams can also assist you in modelling the effect of the reorganisation on your published accounts, and our Crowe Global network can help you navigate any overseas elements of the projects.

We have the knowledge to meet your unique, and often complex needs

Strategy support
Helping you plan where you want to be in the future to meet your commercial objectives.
Strategy support
Demerger and reorganisation
Group separations to facilitate a future sale, growth or expansion.
Demerger and reorganisation
Step plans
Helping you move your business from where it is ‘now’ to the ‘new’ proposed structure.
Step plans
Asset protection
Ensuring that your valuable tax assets are considered and protected including: capital allowances, tax losses and R&D tax relief.
Asset protection
HMRC tax clearances
Seeking advance assurances that your restructure will be approved and tax reliefs will apply.
HMRC tax clearances
Share incentive plans
Developing tax efficient share plans to reward and incentivise management.
Share incentive plans
Transaction implementation
Close collaboration with your legal advisors to ensure a smooth reorganisation process for all parties.
Transaction implementation
Post transaction support 
Including post transaction disclosures, compliance and support from other specialist tax teams.
Post transaction support 

Hive up checklist

Although there is upfront investment to reorganise a group, the management time and compliance expenses that are saved can be considerable.

Additionally, it may lead to a group structure that is more appealing for investment or sale.

Explore our checklist of administrative matters to be considered on a transfer of trade and assets.

Learn more

Our latest thinking

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Companies and people talking in office
Autumn Budget: Companies and other businesses
The Budget offers little for growth, as complex capital allowances, higher dividend tax, NI hikes, and wage rises add pressure.
Group of people meeting at bottom of staircase
Autumn Budget 2025: What about Corporation Tax?
Although Corporation Tax rate is expected to remain at 25% in the 2025 Autumn Budget, companies will still be impacted directly and indirectly.
people walking on a bridge
Capital contributions
Capital contributions are a peculiarity in the UK and are not specifically recognised in our UK legal or tax codes.

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