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Tax

Clyde & Co advises clients from the full range of industries, services and professions on their commercial and corporate taxation affairs, helping them achieve compliance, minimise risk and maximise benefits.

Advice and opinion on all aspects of commercial taxation.

We provide specialist taxation advice to domestic and international organisations, using the strength of our global office network to ensure our guidance and support reflects local legislation and practice.

Our tax specialists work closely with our clients’ own corporate, commercial and finance teams to minimise tax costs and maximise tax reliefs. This includes the tax aspects of mergers and acquisitions, restructures, listings and joint ventures.

As the market’s leading legal practitioner in the insurance sector, we serve the company and Lloyd’s markets and address the needs of underwriters, agents and brokers. We are well versed in the working of insurance premium tax regimes and act for insurers and insureds in professional indemnity cases.

Other areas of focus include real estate, where we provide specialist tax advice on all transactions, the tax aspects of employee benefits and incentives, customs duties and trade taxation, and tax disputes and investigations.

We welcome the opportunity to collaborate with in-house tax teams, providing fresh insight and alternative opinions to help reach the optimum solution in each matter. We are also happy to provide training on new developments in tax operation and practice.

Our Tax Work

  • All
  • Africa
  • UK & Europe
  • African Barrick Gold - offshore share sale transaction

    Advising African Barrick Gold - on an offshore share sale transaction where Tanzania Revenue Authority sought to assess tax in Tanzania

    Tanzania

    AIG - European distribution agreement with HSBC

    • Advising AIG (including in respect of certain tax matters) on an exclusive European distribution agreement with HSBC concerning the distribution of all insurance products and the acquisition of HSBC's French insurance company.   

    United Kingdom

    AMTrust Financial Corporation Inc. - integrated Lloyd's Vehicle

    Acting for the purchaser, (including in respect of tax matters) in relation to an integrated Lloyd’s vehicle (managing agent and capital provider for both a life and non-life Lloyd’s syndicate) and a Cayman reinsurer (transaction value circa GBP 256 million)

    United Kingdom

    AMTrust Financial Services - purchase of mortgage insurance business

    • Advising AM trust Financial Services on the tax aspects of its recent cash purchase from Genworth Financial Inc. of its European mortgage-insurance business (tangible book value of the operations circa USD 155 million)

    United Kingdom

    Ares Property Management - acquisition of retail parks

    • Advising Ares Property Management on tax issues concernign their acquisition of a number of significant retail parks in the UK from Land Securities.

    United Kingdom

    Arriva Rail North Ltd. - Northern Rail franchise

    • Advising Arriva Rail North Limited (including in respect of tax matters) on the transfer and acquisition of the Northern Rail franchise.

    United Kingdom

    BRF S.A - joint venture with INVICTA Food Group

    • Advising BRF S.A. (the world’s seventh largest food company by market capitalisation) on the tax aspects of its joint venture with the UK’s INVICTA Food Group

    United Kingdom

    BW Offshore - Floating Production Strorage and Offloading Vessel

    • Advising BW Offshore on certain UK tax issues in relation to the USD800 million financing of a Floating Production Storage and Offloading vessel for the Catcher Field development, including in relation to the security documents and co-ordination agreement between the borrower/BWO group, the lenders and Premier Oil, the field operator, and its joint venture partners. 

    United Kingdom

    Cathederal Group - redevlopment project Brighton

    Advising Cathedral Group on the tax aspects of the Circus Street property redevelopment in Brighton involving the Council and the University

    United Kingdom

    Cathedral Group - Brighton regeneration project

    • Advising Cathedral Group (Circus Street Project) on the tax aspects of a major regeneration project in Brighton involving Brighton Council and the University of Brighton.

    United Kingdom
  • New Age (African Global Energy) Limited - acquisition of Cameroon assets

    • Advising New Age (African Global Energy) Limited – on tax matters concerning its acquisition of a 12.5% interest in the Etinde permit, offshore Cameroon.

    Cameroon

    African Barrick Gold - offshore share sale transaction

    Advising African Barrick Gold - on an offshore share sale transaction where Tanzania Revenue Authority sought to assess tax in Tanzania

    Tanzania

    Tandrill Tanzania Limited - tax enforcement advice

    Advising Tandrill Tanzania Limited - tax advice concerning proceedings by the Tanzania Revenue Authority to enforce a higher withholding tax rate from a company (Tandrill) providing technical mining services

    Tanzania
  • AIG - European distribution agreement with HSBC

    • Advising AIG (including in respect of certain tax matters) on an exclusive European distribution agreement with HSBC concerning the distribution of all insurance products and the acquisition of HSBC's French insurance company.   

    United Kingdom

    AMTrust Financial Corporation Inc. - integrated Lloyd's Vehicle

    Acting for the purchaser, (including in respect of tax matters) in relation to an integrated Lloyd’s vehicle (managing agent and capital provider for both a life and non-life Lloyd’s syndicate) and a Cayman reinsurer (transaction value circa GBP 256 million)

    United Kingdom

    AMTrust Financial Services - purchase of mortgage insurance business

    • Advising AM trust Financial Services on the tax aspects of its recent cash purchase from Genworth Financial Inc. of its European mortgage-insurance business (tangible book value of the operations circa USD 155 million)

    United Kingdom

    Ares Property Management - acquisition of retail parks

    • Advising Ares Property Management on tax issues concernign their acquisition of a number of significant retail parks in the UK from Land Securities.

    United Kingdom

    Arriva Rail North Ltd. - Northern Rail franchise

    • Advising Arriva Rail North Limited (including in respect of tax matters) on the transfer and acquisition of the Northern Rail franchise.

    United Kingdom

    BRF S.A - joint venture with INVICTA Food Group

    • Advising BRF S.A. (the world’s seventh largest food company by market capitalisation) on the tax aspects of its joint venture with the UK’s INVICTA Food Group

    United Kingdom

    BW Offshore - Floating Production Strorage and Offloading Vessel

    • Advising BW Offshore on certain UK tax issues in relation to the USD800 million financing of a Floating Production Storage and Offloading vessel for the Catcher Field development, including in relation to the security documents and co-ordination agreement between the borrower/BWO group, the lenders and Premier Oil, the field operator, and its joint venture partners. 

    United Kingdom

    Cathederal Group - redevlopment project Brighton

    Advising Cathedral Group on the tax aspects of the Circus Street property redevelopment in Brighton involving the Council and the University

    United Kingdom

    Cathedral Group - Brighton regeneration project

    • Advising Cathedral Group (Circus Street Project) on the tax aspects of a major regeneration project in Brighton involving Brighton Council and the University of Brighton.

    United Kingdom

    Cube Financial Holdings Ltd - slae to FEMAT

    Advising on the tax aspects of the sale of Cube Financial Holdings Ltd to FEMAT, a subsidiary of Société Générale

    United Kingdom

Our Tax team

Ray Smith
Ray Smith

Partner

David Blumenthal
David Blumenthal

Partner

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