Our Services
Specialist Corporation Tax Services

Efficient tax planning can lead to significant improvements to your bottom line. Our experienced corporate tax team can help you plan to best take advantage of the tax opportunities and reliefs available, including those specific to your industry, acting on your behalf in discussions with the tax authorities where necessary.

We understand that in an increasingly regulated and global business environment, more and more businesses are expanding into new markets as they strive to meet their growth targets and access more cost efficient resources. Before setting up overseas, it is important to consider the tax implications. There is no one-size-fits-all tax solution and we can provide advice tailored to your specific circumstances. Our team can advise not only on UK aspects but also on the key considerations when thinking about overseas expansion and ensuring you do not fall foul of the legislation.

Annual Investment Allowance

The annual investment allowance (AIA) provides a 100% deduction against taxable profits for the cost of most plant and machinery, up to an annual limit. Where a company spends above the annual limit in an accounting period, the excess generally attracts allowances at a lower rate of 18% or 8%. The threshold has changed several times in recent years and the rules for periods straddling the change in limit can be complicated. If you are planning significant capital expenditure we can advise you on the best timing to maximise the tax relief available to you.  In addition, we can assist with the preparation of more complex capital allowance claims for example those involving commercial property.

Transfer Pricing

The transfer pricing legislation concerns itself with the prices charged in transactions between connected parties as, in such circumstances, the price charged may not necessarily be that which would have been charged if the parties had not been connected. The purpose of the legislation is to counter potential tax loss generated by non arm's length pricing of a business provision between persons that are not independent. Such transactions, both with other UK and overseas companies have the potential to be caught by the transfer pricing rules which would deem undervalued transactions to be adjusted for tax purposes.

Controlled Foreign Companies

The controlled Foreign Companies legislation is aimed at taxing in the UK, profits that have been artificially diverted to countries with lower tax rates or countries that do not impose tax and broadly speaking the rules apply where:
  • The overseas company is resident outside of the UK; and
  • Is controlled by person or persons resident in the UK.
Advance planning is key to ensure that outward expansion from the UK in the form of overseas subsidiaries does not trigger unwanted tax consequences.

Company Reorganisations

Our highly-skilled team can help you assess the implications of and assist with the planning and performing of company reorganisations to ensure that they are carried out with no unexpected adverse tax consequences. This includes advising on all elements of your potential transaction including corporation tax consequences, payroll, VAT, considerations for individual shareholders and general housekeeping and administrative considerations.

Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS)

The purpose of both the Enterprise Investment Scheme (EIS) and the Seed Enterprise Investment Scheme (SEIS) is to help small, unquoted trading companies to raise capital. The SEIS focuses on smaller, early stage companies and so can be viewed as higher risk for the investor than the EIS which is reflected in the rate of tax relief available.

The EIS and the SEIS can provide income tax and/or capital gains tax relief to the investor where certain qualifying conditions are met. Although the SEIS applies only to investments made between 6 April 2012 and 6 April 2017, the relief is unprecedented and unlike the EIS, company directors investing in their own companies may also be able to qualify for SEIS.

An overview of the key conditions to be met by the investor and the company can be found in our factsheet here. As with all such transactions it is crucial to have the right advice before proceeding and whether you are a potential investor or are looking to raise company finance through the scheme we can guide you through the process.

The Patent Box

Phased in from April 2013, The Patent Box relief is closely linked to R&D tax relief, providing a reduced rate of corporation tax for companies exploiting patented inventions or other innovations protected by certain intellectual property rights. You can read our factsheet here. Although a relatively new area, we are already exploring this with our existing clients and can work with you in preparing and submitting a claim to give your business the best chance benefitting from the potential tax relief available.

Research & Development

The Government actively encourages Research & Development (R&D) and the advancement of technology through its tax incentive scheme. The R&D tax relief offers enhanced relief on allowable expenditure and can even result in a repayable tax credit in some instances. You can read more details in our factsheet here. We can assist in preparing and submitting your claim as well as liaising with HMRC on your behalf to ensure that the process is as smooth and efficient as possible.
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Alan Boby
Charlotte Houghton

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