• Owner-managed property and regeneration company – EOT transaction

Design and implementation of the structure for the sale of the business to an EOT, with full suite of legal documentation for the company and the trust. Multiple presentations and communications with a range of stakeholders. Obtained successful statutory and non-statutory HMRC clearances.

• Chain restaurant group – PE disposal and investment transaction

Employment related securities tax advice on the existing management team’s partial disposal of shareholdings, rollover of equity and new management share awards with Business Asset Disposal Relief (formerly ‘entrepreneurs’ relief’) structuring. Liaising with existing overseas employee benefit trust trustee and winding up of the trust. Working with management’s M&A advisor on acquisition vehicle corporate and equity structuring. 

• SaaS company – post PE investment EMI scheme

Implementation of an EMI scheme for management team, to complement existing growth shares. Liaising with legal advisors to amend the articles of association. Tax valuation of the scheme shares including agreement with HMRC. Design and modelling of the scheme including share plan documentation, employee communications, board minutes and ancillary documentation, and grant of options.

• Courier and logistics group – due diligence

Review of existing share schemes and ERS prior to proposed initial listing on stock exchange. Uncovered issues relating to the EMI scheme which could have meant multi-millions of unexpected PAYE and national insurance costs. Approached HMRC to clear the technical points pre transaction. Advised on ways to amend the documentation, communicate to employees and rectify HMRC reporting.