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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

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

Market value vs Book value: invalidity risks on intra-group transfers

22 September 2013   Paul Sutton

Market value vs Book value: invalidity risks on intra-group transfers Group reorganisations often involve the transfer of assets from one company to another. The assets may be tangible or intangible assets, or they may be a debt receivable which is owed by another group company. One of the key issues from a UK company law…

Group Reorganisations

LCN Legal presents training session on Corporate Simplification

16 September 2013   Paul Sutton

Paul Sutton, Partner at law firm LCN Legal, has presented a training session for accountants on corporate simplification (also known as ‘legal entity reduction‘). The session focussed on the drivers for corporate simplification projects, as well as key lessons learned from managing similar projects.

Group Reorganisations

Using Quoted Eurobonds to address UK Witholding Tax

10 September 2013   Paul Sutton

Using Quoted Eurobonds to Address UK Withholding Tax In general, UK withholding tax becomes payable at the rate of 20% when a UK tax resident company pays interest on a loan to an overseas lender. Ordinarily, the UK borrower will not be disadvantaged because it can still benefit from a potential tax deduction for the…

Group Reorganisations
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