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RESTRUCTURING


Card image Abby Martin Lisa Rickelton Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report. 
When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.
Card image Gavin Orpwood Louise Keegan Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.
Matthew Mortimer and Kitty Swanson (Mayer Brown) provide a practical guide.

Jonathan Rosen (Akin Gump Strauss Hauer & Feld) considers the recent restrictions on corporate interest deductibility, and their impact on the UK’s attractiveness as a holding company jurisdiction.

Darren Oswick and Gary Barnett (Simmons & Simmons) consider some of the tax implications that may result from the inevitable wave of business restructurings which will follow the Brexit vote.
 

Peter Jackson (Taylor Wessing) answers a query on a group restructuring to assist the refinancing of existing debt

Anthony Newgrosh (BKL) answers a query on a tax-efficient debt restructuring for a corporate client that can no longer service its bank borrowings

Dominic Robertson (Slaughter and May) reports on the likely changes needed to group structures in light of BEPS, state aid challenges and the diverted profits tax

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