Practice areas

The tax efficient structuring of employee incentive arrangements is often a key requirement for our clients to achieve their commercial objectives.

We advise businesses and senior executives on the structuring of the full range of incentive arrangements including salaries and benefits, long term incentive plans, relocations and termination packages.  We advise both on a stand-alone advisory basis and in the context of larger corporate transactions.

We have particular expertise in the structuring of tax efficient equity based incentive plans.  There are many different options available and in all cases we work with our client to ensure that the most appropriate option is chosen.  In some cases, a simple ordinary share equity plan will be appropriate. In others, more bespoke arrangements, such as growth in value shares or deferred payment and/or joint ownership arrangements, are required.

We also design and implement more widely offered employee incentives schemes for listed and unlisted clients.  These include bonus schemes, option schemes, phantom schemes and the full range of HMRC approved schemes.

On the transactional side, we advise both sponsors and management teams on the structuring of management equity in private equity transactions.  We also have considerable experience in advising on transactions to reset underwater management equity and in devising new management equity packages in "loan to own" transactions.

Much of our work in this area is cross-border and we regularly work on incentive arrangements outside the UK.  We have close relationships with the leading independent law firms in overseas jurisdictions whose expertise we enlist on the non-UK tax aspects of these matters.

We also have widely recognised expertise in advising investment managers on the structure of their management vehicles and on their general partner's share, carried interest and co-investment planning.  In this context, we have advised a number of private equity houses and advisory businesses on their conversion from corporate to LLP form.  More generally, we advise owner-managed businesses on all aspects of their structuring, from establishment to succession planning and exits.

With the introduction of a 50 per cent income tax rate, we are increasingly being asked to advise on remuneration planning.  We have significant expertise in this area.

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