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Tax

Clyde & Co advises clients via legal tax advice for a full range of industries, services and professions on their commercial and corporate taxation affairs.

Advice and opinion on all aspects of commercial taxation.

We provide specialist taxation advice to domestic and international organisations, using the strength of our global office network to ensure our guidance and support reflects local legislation and practice.

Our tax specialists work closely with our clients’ own corporate, commercial and finance teams to minimise tax costs and maximise tax reliefs. This includes the tax aspects of mergers and acquisitions, restructures, listings and joint ventures.

As the market’s leading legal practitioner in the insurance sector, we serve the company and Lloyd’s markets and address the needs of underwriters, agents and brokers. We are well versed in the working of insurance premium tax regimes and act for insurers and insureds in professional indemnity cases.

Other areas of focus include real estate, where we provide specialist tax advice on all transactions, the tax aspects of employee benefits and incentives, customs duties and trade taxation, and tax disputes and investigations.

We welcome the opportunity to collaborate with in-house tax teams, providing fresh insight and alternative opinions to help reach the optimum solution in each matter. We are also happy to provide training on new developments in tax operation and practice.

Our Tax Work

  • All
  • Africa
  • UK & Europe
  • African Barrick Gold - offshore share sale transaction

    Advising African Barrick Gold - on an offshore share sale transaction where Tanzania Revenue Authority sought to assess tax in Tanzania

    Tanzania

    AIG - European distribution agreement with HSBC

    • Advising AIG (including in respect of certain tax matters) on an exclusive European distribution agreement with HSBC concerning the distribution of all insurance products and the acquisition of HSBC's French insurance company.   

    United Kingdom

    AMTrust Financial Corporation Inc. - integrated Lloyd's Vehicle

    Acting for the purchaser, (including in respect of tax matters) in relation to an integrated Lloyd’s vehicle (managing agent and capital provider for both a life and non-life Lloyd’s syndicate) and a Cayman reinsurer (transaction value circa GBP 256 million)

    United Kingdom

    AMTrust Financial Services - purchase of mortgage insurance business

    • Advising AM trust Financial Services on the tax aspects of its recent cash purchase from Genworth Financial Inc. of its European mortgage-insurance business (tangible book value of the operations circa USD 155 million)

    United Kingdom

    Ares Property Management - acquisition of retail parks

    • Advising Ares Property Management on tax issues concernign their acquisition of a number of significant retail parks in the UK from Land Securities.

    United Kingdom

    Arriva Rail North Ltd. - Northern Rail franchise

    • Advising Arriva Rail North Limited (including in respect of tax matters) on the transfer and acquisition of the Northern Rail franchise.

    United Kingdom

    BRF S.A - joint venture with INVICTA Food Group

    • Advising BRF S.A. (the world’s seventh largest food company by market capitalisation) on the tax aspects of its joint venture with the UK’s INVICTA Food Group

    United Kingdom

    BW Offshore - Floating Production Strorage and Offloading Vessel

    • Advising BW Offshore on certain UK tax issues in relation to the USD800 million financing of a Floating Production Storage and Offloading vessel for the Catcher Field development, including in relation to the security documents and co-ordination agreement between the borrower/BWO group, the lenders and Premier Oil, the field operator, and its joint venture partners. 

    United Kingdom

    Cathederal Group - redevlopment project Brighton

    Advising Cathedral Group on the tax aspects of the Circus Street property redevelopment in Brighton involving the Council and the University

    United Kingdom

    Cathedral Group - Brighton regeneration project

    • Advising Cathedral Group (Circus Street Project) on the tax aspects of a major regeneration project in Brighton involving Brighton Council and the University of Brighton.

    United Kingdom
  • New Age (African Global Energy) Limited - acquisition of Cameroon assets

    • Advising New Age (African Global Energy) Limited – on tax matters concerning its acquisition of a 12.5% interest in the Etinde permit, offshore Cameroon.

    Cameroon

    Tandrill Tanzania Limited - tax enforcement advice

    Advising Tandrill Tanzania Limited - tax advice concerning proceedings by the Tanzania Revenue Authority to enforce a higher withholding tax rate from a company (Tandrill) providing technical mining services

    Tanzania

    African Barrick Gold - offshore share sale transaction

    Advising African Barrick Gold - on an offshore share sale transaction where Tanzania Revenue Authority sought to assess tax in Tanzania

    Tanzania
  • Dixon Insurance Services Limited - insurance premium tax appeal

    Advising Dixon Insurance Services Limited (DISL), part of the Dixons Group, on it's successful insurance premium tax (IPT) appeal, establishing the leading case on 'location of risk'.

    United Kingdom

    Harbour Hotels Group Ltd. - facility agreement with The Royal Bank of Scotland plc

    • Advising Harbour Hotels Group Limited - on various tax matters, concerning the £86 million multi-tranche facility agreement entered into with The Royal Bank of Scotland plc, securing a number of award winning hotel properties in the South West and advising the group on a complex mixed-use development of a harbour front in Southampton including the construction of a hotel, residential apartments and commercial/retail units, acting for the developer/borrower.

    United Kingdom

    RK Harrison Holdings Ltd. – advising on acquisition by Hyperion Insurance Group Ltd.

    • Advising RK Harrison Holdings Limited –  in relation to the acquisition by Hyperion Insurance Group Limited through a court scheme of arrangement.  Certain classes of shares were held by an employee benefit trust (EBT) for the RK Harrison employees. Advising the trustees of the EBT on tax issues concerning the scheme of arrangement.

    United Kingdom

    Novae/CNA - tax indemnity insurance

    • Advising the insurers on the tax ramifications and tax strategies of various tax indemnity insurance policies relating to different tax planning risks, including in relation to capital gains tax planning (using offshore trusts) and employee incentive.

    United Kingdom

    Pirium - sale to Five Arrows

    • Advising the founder shareholders of Pirium on their sale of Pirium to Five Arrows Principal Investments, the mid-market private equity fund backed by the Rothschild Group, and Camwell Management.

    United Kingdom

    Lai Sun Group - property acquisition worth £167 million

    • Advising Lai Sun Group on the tax aspects of a on significant property acquisition of two sites in the City square mile for a combined purchase price of £167 million.

    United Kingdom

    SIMEC and Liberty House Groups - business acquisitions

    • Advising (including in respect of tax) SIMEC and Liberty House Groups, owned by the Gupta family, on their strategic acquisition of Caparo's Speciality Steels tubular solutions and advanced engineering businesses in two deals. 

    United Kingdom

    BW Offshore - Floating Production Strorage and Offloading Vessel

    • Advising BW Offshore on certain UK tax issues in relation to the USD800 million financing of a Floating Production Storage and Offloading vessel for the Catcher Field development, including in relation to the security documents and co-ordination agreement between the borrower/BWO group, the lenders and Premier Oil, the field operator, and its joint venture partners. 

    United Kingdom

    Arriva Rail North Ltd. - Northern Rail franchise

    • Advising Arriva Rail North Limited (including in respect of tax matters) on the transfer and acquisition of the Northern Rail franchise.

    United Kingdom

    Ares Property Management - acquisition of retail parks

    • Advising Ares Property Management on tax issues concernign their acquisition of a number of significant retail parks in the UK from Land Securities.

    United Kingdom

Our Tax team

Ray Smith
Ray Smith

Partner

David Blumenthal
David Blumenthal

Partner

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