Corporate Tax

We advise organisations of all sizes on corporation tax and partnership tax matters. No matter what stage of growth your business is at, you can rely on us for accurate tax advice, tailored and simplified to help your organisation’s needs and achieve its goals.

The range of services that our business tax specialists provide includes the following:

With ever-increasing tax legislation and penalties, getting your taxes right is more important than ever. We provide a bespoke service to ensure that you meet your compliance obligations in a timely and tax-efficient manner, whilst adding value to the process of managing tax risks.

Our service is tailored to your business and covers much more than tax return preparation. We prefer to meet with you regularly to proactively assess the tax position for you and your business, forecast tax liabilities, review cash flows, and identify tax planning opportunities.

Unlike some of our competitors, we do not use tax compliance centres or hubs. We consider tax compliance to be incredibly important, so we ensure that it is undertaken from our London office by the same team that provides tax advice.

The range of services that our Compliance team provides includes:

  • Tax return preparation and submission (full service for companies and partnerships)
  • Tax provision for financial statements and global tax consolidations
  • Optimising available reliefs by making timely and robust claims to capital allowances and innovation tax reliefs such as research & development and patent box
  • iXBRL tagging of financial statements
  • Tax payment estimates
  • Liaising with HMRC – whether it be in relation to tax investigations or routine matters in relation to notifications and payments
  • Understanding and complying with any withholding tax obligations arising from dividend, interest and royalty payments
  • Compliance with other corporate tax obligations such as Senior Accounting Officer reporting, Country by Country reporting, Notification of Uncertain Tax Treatments, publication of your tax strategy and the Criminal Finances Act

At Andersen LLP, we ensure that your business is not just tax compliant, but also as tax efficient as possible and in the simplest way. Our experienced advisory team will help you develop the right approach to every aspect of your business, no matter the size or industry.

We recognise that there is no one-size-fits-all approach to tax advice.  We understand your businesses' needs, circumstances and goals and so can provide you with bespoke advice.

We also advise on tax matters in other jurisdictions, calling on the expertise of member firms in the Andersen Global association.

At Andersen LLP, we have assembled an experienced team of M&A tax advisers.  We appreciate that buying, selling or merging companies is a key milestone moment for shareholders, investors, and directors.

The acquisition process can be highly intense, and we can support you through that process from the very start when targets are identified, to signing the sale and purchase agreement.

We also advise vendors on the tax consequences of selling their businesses including pre-sale structuring and identifying historic tax liabilities and exposures through a vendor due diligence process.

We can also help get your business ‘exit ready’ by conducting health-checks of your businesses’ tax affairs and, where needed, disclose and negotiate positions with HMRC to mitigate unwanted surprises arising during due diligence.

Our services include:

  • Tax due diligence
  • Vendor tax due diligence
  • Tax structuring including consideration of transaction routes (e.g. share vs asset deal)
  • Review of tax warranties and indemnities
  • Post deal integration and tax housekeeping
  • Acquisition costs structuring
  • Funds flow (sources and uses)

Overseas businesses looking to expand or invest into the UK need to understand the tax consequences and the structuring options available.

We advise on the consequences, including the interaction of different systems, identify any potential tax mismatches and the structuring options available to mitigate tax leakage and optimise the tax treatment of future income streams.

The corporation tax rules in the UK have changed significantly in recent years, and it is therefore important to take upfront advice.

In addition, existing arrangements should be reviewed to confirm whether they are still effective and any and all relevant compliance obligations have been met and are up to date.

Our services include:

  • Analysis of corporate structures and supply chains to determine how the UK’s anti-hybrid legislation applies – [link to the below section ‘Hybrids’]
  • Tax efficient financing of UK companies, including compliance with the UK’s corporate interest restriction rules [link to below section ‘Corporate interest restriction – CIR’]
  • Assistance in complying with transfer pricing and thin capitalisation rules [link to below section ‘Transfer pricing and thin-cap’]
  • Understanding local tax compliance requirements
  • The full range of tax accounting and provisioning services – from coordinating your tax reporting processes to preparing local provisions and GAAP reconciliations.
  • Making claims under double taxation agreements

We also advise on the acquisition of investments in other jurisdictions, calling on the expertise of member firms in the Andersen Global association.

Andersen LLP is part of Andersen Global – an association of tax and legal professionals comprising 11,000 professionals in more than 160 countries.  We therefore have access to this expertise and consider all aspects of our clients’ international businesses.

International tax rules are constantly changing and choosing the wrong structure can affect your business’s global competitiveness.

We help companies structure their tax affairs in a way that supports their strategic goals whilst maintaining tax efficiency.

Our international tax services include:

  • Onshore and offshore expansion and/or acquisition
  • Structuring of the holding of intellectual property and financing
  • Assistance in complying with transfer pricing and thin capitalisation rules [link to below section ‘Transfer pricing and thin-cap’]
  • Tax compliance services when sending employees to/from the UK
  • Ad-hoc advisory services
  • Coordinating complex multi-jurisdictional tax structuring projects – see also International Tax

We advise our clients on the tax implications of post-acquisition integration and restructuring and take a holistic approach to supply-chain analysis so that tax-efficiency is obtained without any compromise to operational efficiency.

In addition to assisting clients acquire and merge companies, we also work with clients who want to divest companies from their group or portfolio as part of good corporate housekeeping and cost management.

We advise businesses on the rationalisation of group entities, providing a step plan and tax analysis to ensure that they maximise the tax efficiency of the process.

The UK tax code includes valuable incentives to encourage investment in innovation activities and capital expenditure.

We assist our clients in making technically robust claims to research & development tax credits and analysing clients’ intellectual property to produce patent box claims which results in an effective tax rate of 10% on patent box profits.

The UK has a generous capital allowances regime which can materially impact the after-tax costs of capital expenditure.  We undertake reviews of clients’ capital expenditure projects to assist them in making compliant claims to capital allowances.

We have significant experience advising on the UK’s anti-hybrid rules.

The aim of the rules is to provide parity and eliminate instances of tax arbitrage in international corporate tax structures (e.g. eliminating double deductions, or deductions with no corresponding income pick up in cross border structures).

The UK anti-hybrid rules are extremely complex and broadly seek to disallow UK corporate tax deductions for costs in structures that have either a ‘hybrid instrument’ or a ‘hybrid entity’.

Large multinational groups with UK parents or subsidiaries in more than one tax jurisdiction can often fall under the anti-hybrid rules.  This may be because of a mismatch in the tax treatment between the two countries.

The ability for US groups to make elections for their UK subsidiaries to be treated as flow-through entities can result in them becoming hybrid entities.

We are familiar with these issues and are ideally positioned to analyse supply chains and identify potential mismatches to ensure your business remains compliant.

All companies within the charge to UK corporation tax are subject to the CIR rules.

The basic rule is that deductions for interest above the de-minimis amount of £2m will be restricted to the extent that it exceeds 30% of the UK Group’s EBITDA (fixed ratio) as calculated for UK tax purposes.

If the worldwide group has a level of interest expense on external debt which exceeds 30% of the group’s EBITDA, this threshold may be raised to that level by making a group ratio election.

Unfortunately, the group ratio election carves out related party debt (bad news for the PE community).

The CIR rules also include a debt cap restriction. The maximum interest deduction in the UK will be restricted to the net interest expense of the worldwide group. This means that if a group has no third-party debt then UK interest deductions are restricted to £2m.

We help businesses to understand and apply the CIR rules and undertake the following CIR compliance work:

  • Appointing a reporting company for CIR nomination
  • Submitting CIR returns to HMRC
  • Preparing CIR calculations
  • Incorporating the CIR restriction into corporate tax returns

As businesses continue to grow and evolve globally, HMRC is increasing focus on compliance requirements for transfer pricing. Transfer pricing concerns the pricing of transactions between related parties. Many territories’ tax codes require the terms for intra-group transactions to reflect those that would be agreed between independent parties and have this position reflected in companies’ tax returns.

Your company may fall under the thin capitalisation rules if it has excessive debt in relation to its arm's-length borrowing capacity, leading to the possibility of excessive interest deductions.

We help businesses assess their capital management and ensure they stay compliant with the transfer pricing rules.

We also advise on transactions between the UK and other jurisdictions, calling on the expertise of member firms in the Andersen Global association.