On 14th May 2015, LCN Legal was honoured to host an informal workshop for large corporates on legal entity reduction projects.
We would like to thank our wonderful guests for contributing so much to the discussion. They represented organisations including:
- Bank of America Merrill Lynch
- British Land
- Rolls-Royce Holdings
“I found it refreshing to go through the technical challenges and best practice on unwinding entities, including project managing the process, with some highly skilled and experienced in-house tax and legal experts.”
– Lee Holloway, Head of Tax and Corporate Finance, Halfords
“Wonderful to attend and share experiences.”
– Alex Carlyle, International Tax Manager, Rolls-Royce Holdings
The event was co-chaired by Paul Sutton of LCN Legal and by Ian Barron, non-executive adviser to LCN Legal and former VP and Head of Corporate Tax EMEA for American Express.
We would like to extend special thanks to Mohammad Sheezan, who shared some of his experiences in project-managing tax issues on large-scale simplification projects, and to Yvonne Butler from the Restructuring team at Deloitte, who provided extremely valuable perspectives on the liquidation process and the practical challenges faced by corporates.
The discussion was held under the “Chatham House Rule”, and the key themes included the following:
- The scale of the issue faced by many large corporates – some of which may have been unable to identify exactly how many legal entities they had, until they embarked on a corporate simplification programme.
- The strong trend away from tax planning driven by reducing effective tax rate, to sustainable, low-risk structures – often leading to historic structures being unwound.
- Many corporates now regarding legal entity reduction as “business as usual” rather than as a one-off project.
- The need for a defined process for due diligence, usually involving checklists organized by function.
- The use of ‘sweeper’ assignments and Cross-Border Mergers to help ensure that assets are preserved.
- The benefits of communicating in advance with HMRC and other tax administrations about the programme. This can help
- The critical role of dedicated project management resource with high-level support – in many cases, with the CEO personally reporting to staff on the progress made by the programme.