+1 747 212 0206
+44 20 3286 8868
+86 21 2052 0623

Blog

Take advantage of our free expert resources, written by the experts at LCN Legal, based on their practical experience of working with multinational groups and their advisers across the globe. If you are interested in these areas, you may wish to bookmark this page to check back regularly for new information.

7 reasons not to start a corporate simplification project

27 November 2013 Paul Sutton

Sometimes it’s obvious that a group needs to remove unnecessary companies. The group may have 128 dormant companies, each of which have done nothing for 15 years. There may be a global policy at head office level which instructs local management to implement a policy of legal entity reduction. Or a key regulator may decide…

Group Reorganisations

An introduction to limited partnership funds: who does what?

21 November 2013 Paul Sutton

This introduction is for people who are considering setting up a UK fund using the traditional structure of an English limited partnership. This is only one of a range of legal structures which can be used, but it is a tried and tested model. The structure is summarized in the diagram below. This particular one…

Uncategorised

Intra-group transfers at market value or book value

18 November 2013 Paul Sutton

This article is taken from the second postcard in our series of cards on group reorganisations, and looks at the price at which assets can be transferred intra-group. Links to the other postcards in the series can be found at the end of this article. This legal issue arises on an ‘upwards’ or ‘sideways’ transfer….

Group Reorganisations

Top 5 Eurobond Myths

8 November 2013 Paul Sutton

Top 5 Eurobond Myths The so-called “Quoted Eurobond Exemption” remains an effective way of dealing with UK withholding tax on interest. It is potentially available where the borrower is a UK tax resident company, and the lender is foreign resident. In many ways, the term “Eurobond” is misleading, and it can give rise to a…

Group Reorganisations

How to Use the Solvency Statement Capital Reduction Procedure in UK Group Reorganisations

14 October 2013 Paul Sutton

The so-called “solvency statement procedure” is a very straightforward way of creating distributable reserves and enabling assets to be returned to shareholders. This article gives a brief overview of how and when it can be used. 1. What are your objectives? The starting point is to be clear about what you are trying to achieve…

Group Reorganisations

Does the plan work for everyone?

8 October 2013 Paul Sutton

LCN Legal has just launched its ‘family photos’ postcard campaign to help finance and tax professionals understand key legal issues affecting group reorganisations. The first postcard deals with the issue of corporate benefit, and is shown below. Thanks to Word of Mouth Communication for the concept and the design. Links to the other postcards in the…

Group Reorganisations

How to Put in Place Effective Intercompany Agreements for Transfer Pricing

4 October 2013 Paul Sutton

IMPORTANT NOTE: This article was first published in the Tax Journal on 4 October 2013. Since then, the content has been substantially updated and revised and now forms part of our Free Briefing on How to Create Effective Intercompany Agreements for Transfer Pricing. This Briefing takes into account the 2017 edition of the OECD’s Transfer…

Intercompany Agreements

When is Backdating OK?

30 September 2013 Paul Sutton

This is one of the most common issues which comes up in the context of group reorganisations or intercompany agreements. Although it may have been intended to put in place a new arrangement by a particular date – often a year end – that date may now have passed. The question is: can the documents…

Group Reorganisations

Intercompany Agreements