Private Equity and Venture Capital Taxation
The Tax group works closely with Private Equity group advising from the outset on the most tax efficient method of structuring and implementing private equity and venture capital transactions, including MBOs, MBIs, secondary buy-outs and other arrangements. We have considerable experience of advising institutional investors and structuring leveraged transactions to meet the particular needs of private equity funds.
In addition to the provision of general tax advice on private equity transactions, the Tax group has extensive experience on advising:
- on the most suitable share option and/or incentivisation packages for management which are to be implemented by the investee company
- on the most suitable and tax-efficient forms of financing whether debt, equity or a mixture of the two and, where debt is involved, the structuring of that debt (for example, convertible interim finance, and/or hybrid financing),
- on the "packaging" of the investee company (including debt/equity swaps, share reorganisations and splits, and company group reorganisations), and
- on the structuring and establishment of private equity funds (including arrangements for management "carry" and other forms of participation).
In relation to UK investments, we advise:
- Venture Capital Trusts on their tax issues; including, whether the investment in the investee company is a qualifying holding for VCT purposes
- on the eligibility of the investee company and its shareholders for Enterprise Investment Scheme relief.