Corporate Tax Structuring — Getting the Right Setup to Minimise Your Business Tax Bill

The tax structure of a business can make a profound difference to the after-tax returns available to shareholders, employees, and investors — and the right structure depends on the nature of the business, the exit strategy, the investor base, and the jurisdiction of key activities. I advise on corporate tax structuring for UK businesses across a wide range of transactions and planning exercises, including holding company structures, IP holding arrangements, group relief planning, research and development tax relief claims, and the tax aspects of corporate finance transactions. For businesses raising external investment, the availability of tax reliefs for investors — EIS, SEIS, and VCT qualification — can be a critical factor in attracting funding and the tax structure must be in place before the investment is made. I advise on advance assurance applications to HMRC for EIS and SEIS status, the conditions that must be maintained throughout the qualifying period, and the interaction between investor reliefs and founder CGT reliefs. Getting this wrong can result in investors losing tax relief worth up to 50% of their investment — a reputational and legal risk that founders should take seriously. For established groups, I advise on the optimisation of group structure for tax purposes, including the timing and mechanics of group relief claims, dividend routes and withholding tax considerations for international groups, and the transfer pricing obligations that apply to intra-group transactions. I work closely with your accountants and, where specialist tax counsel is needed for complex technical points, I coordinate that instruction as part of the overall advisory process. How It Works 1. Business model, ownership structure, and commercial objectives reviewed 2. Tax-efficient structure recommended with HMRC clearance where available 3. Documentation prepared — articles, shareholder agreements, trust deeds 4. EIS/SEIS advance assurance application submitted if applicable 5. Ongoing compliance and restructuring advice as business evolves What You Get - Holding company and group structure advice - EIS, SEIS, and VCT advance assurance applications - R&D tax relief claim coordination - Transfer pricing and intra-group transaction advice FAQ Q: Should I operate through a limited company or LLP? A: The answer depends on profit levels, the nature of the business, and how you want to extract value. I advise on the comparative tax position and non-tax factors for your specific situation. Q: What is an EIS advance assurance and do I need one? A: It is a non-binding confirmation from HMRC that a company is likely to qualify for EIS. Most sophisticated investors require it before investing. I handle the application. Q: Does transfer pricing apply to small businesses? A: Transfer pricing applies to transactions with connected parties, including intra-group loans and service charges. HMRC has a small and medium enterprises exemption but I advise on whether it applies to you.