Practice guide: Cross-border acquisitions

Introduction

This practice guide considers some of the issues faced by UK companies making acquisitions outside the UK and by overseas companies making acquisitions in the UK. It considers the differences between asset and share acquisitions both from a UK and an overseas tax perspective and some of the structures which may be used to make an acquisition.

However as with all tax planning a transaction structure will oft en be determined by legal and commercial issues rather than tax issues. In this case the role of the tax adviser is to determine the tax consequences of such a structure and make suggestions for improvements as far as possible.

Structure

There are a number of different structures which can be used to effect an acquisition and these structures are oft...