International tax

Our tax team delivers an unrivalled experience to our broad range of clients domestically and across the globe, from start-ups to mature private companies, to FTSE 100 and 250 clients.

The team is made up of over 16 lawyers who are specialists in their field. We regularly advise on:

  • multi-jurisdictional transactions, including M&A, reorganisations, restructurings and demergers
  • employee incentives and share schemes
  • enterprise investment schemes and venture capital trust schemes
  • real estate tax including on complex development projects

UK inbound

Companies wishing to establish themselves in the UK, will be subject to UK corporation tax.  A non-UK resident company is liable to UK corporation tax on the profits of a trade carried on by it through a permanent establishment in the UK, and on capital gains realised on the disposal of capital assets used or held by it for the purposes of that UK permanent establishment.

Profits that are attributable to the permanent establishment are those that it would have made if it were a distinct and separate UK enterprise, engaged in the same or similar activities under the same or similar conditions, dealing wholly independently with the rest of the non-resident company of which it is a part.

A non-UK resident company which carries on a trade in the UK other than through a permanent establishment is liable to UK income tax rather than corporation tax on the profits attributable to that trade.

Advising clients overseas

We advise UK and international organisations on achieving their strategic goals and we pride ourselves on delivering highly complex, high-profile transactions for our clients.

Our specialist lawyers have a deep-rooted knowledge of the latest trends and proven experience in providing a comprehensive service and negotiating the best transactional outcome for their clients.

Our examples of multi-jurisdictional work include:

  • Advising Five Arrows Principal Investment (the European private equity arm of Rothschild & co) on its acquisition of Allocate Software and significant investment in Sygnature Discovery
  • Advising Everbridge Inc. on its $160m acquisition of the Anvil Group, an advanced business resilience solutions business
  • Advising Sandbox International Holdings Limited on their acquisition of one of the leading children’s edutainment platforms in Brazil.  The group acquired consisted of multi-jurisdictional entities, such as the Netherlands and the US
  • Advising Akmazo Capital (a US based investment firm) on its acquisition of JRNI, an experiential relationship management platform for scheduling and managing personalised experiences at scale
  • Advising Octopus Ventures on various investments and exits in 2021, many of which had an international element, for example the reincorporation of SmartKem from the UK to the US, the $75m investment into Big Health led by Softbank Vision Fund 2, the $17m investment into Turtl and the $11m investment into Raylo

International services

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