A well-structured group uses a combination of holding companies, financing companies, centralised service companies and operating companies to facilitate tax-efficient repatriation, investment and divestment. Tax regimes have evolved. In the UK the taxation of foreign profits is experiencing fundamental change. Overseas, there have been changes to participation exemption regimes and tax grouping rules. A review might well conclude that it is possible to simplify or restructure the corporate group to create efficiencies. A number of aspects need to be carefully considered when restructuring, including tax attributes, transfer taxes and capital gains reliefs, as well as commercial restraints.
