Privately Owned Group Tax
Structuring privately owned groups for long-term stability
We provide integrated tax advice for UK and international privately owned groups, combining corporate tax and private client expertise to meet the needs of both businesses and owners. Our clients – often founder-led or family-controlled – face distinct tax, structuring and governance challenges, and our team is built to address them.
We are the only UK firm ranked Band 1 by Chambers for both corporate tax and private client tax, reflecting the strength of our joined-up approach. We deliver sophisticated, coordinated and forward-looking advice across the full range of personal and business tax matters.
By combining commercial, corporate, personal and estate tax and tax policy perspectives, we help clients navigate succession planning, cross-border structuring, governance, tax risk management and multi-generational transitions with confidence.
We advise on a wide range of complex UK and international tax matters, including:
- tax-efficient structuring of domestic and cross-border operations;
- group reorganisations, demergers, returns of value and ownership restructuring;
- succession planning, including estate and inheritance tax strategy for founders and families;
- governance and residence issues across jurisdictions;
- planning and strategy for international tax developments including OECD initiatives such as Pillar Two;
- contentious matters including residence, transfer pricing and diverted profits tax enquiries and litigation; and
- multi-jurisdictional tax risk management, compliance and strategy, including in response to political or legislative change.
Work highlights include advising:
- maximising value for the shareholders of a large private group by demerging strategically significant divisions, in a tax neutral transaction, to unlock third party investment;
- reorganising a complex multinational group to respond to the challenges of the global minimum tax (Pillar Two) and other international tax policy shifts;
- securing the withdrawal of diverted profits tax assessments made by HMRC against a multinational group with a complex cross border supply chain;
- obtaining certainty for large corporate groups on their transfer pricing matters, through a mixture of pre-filing advisory work, advance pricing agreements (APAs) and the resolution of HMRC enquiries; and
- managing a wide range of tax and structuring matters (corporate tax, employment tax, inheritance tax) associated with the relocation of a founder-shareholder of a high value international group.
