If you are looking at a managed succession plan, or looking to take a business to the next level, a management buy-out (MBO) could be the right strategic solution.
Tax Clearances / Structuring
Having a detailed understanding of the available statutory tax clearances together with knowledge and experience of the potential use of non-statutory clearance procedures is essential when considering an MBO to ensure the requisite tax clearances are received from HMRC to achieve the optimum tax treatment for the consideration.
Our experience enables us to predict the typical approach taken by HMRC which ensures that any commercial deal agreed also reflects the optimum tax position for all sides to minimise the risk of tax leakage or lengthy enquiries by HMRC.
We have significant experience in negotiating with HMRC and drafting and submitting such clearances and the available instruments to structure MBO’s such as deferred consideration, loan notes, preference shares, flowering shares, freezer shares etc.