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Paul Whitehead

“The UK still offers most non-doms a very beneficial tax regime.” Paul Whitehead, Partner - Private Client

Tax Planning, Disputes & Compliance

Tax is increasingly complex, reputationally sensitive and potentially costly. We will help you plan and manage your tax affairs efficiently, and ensure you are tax compliant.

Tax planning and related advice, including dealing with tax authorities, is a core competence for Bryan Cave Leighton Paisner. We are tier-1 ranked for personal tax, trusts and probate by independent legal directory ‘Legal 500’. In the last 5 years we have advised high-net-worth individuals, their families and businesses on over 2000 complex tax issues.

Specifically, clients continue to rely on our help in areas such as:

  • Residence and domicile, pre-immigration tax and wealth planning and emigration planning;
  • International and cross-border personal and corporate tax planning;
  • Corporate tax planning for trading compliance;
  • Taxation of real estate investment, development and trading;
  • International asset holding structures for personal and business assets, including art, private jets and yachts;
  • Tax efficient remuneration and the tax efficient extraction of business profit;
  • Tax efficient structuring of investments for UK and non-UK domiciled individuals;
  • Tax authority enquiries and investigations;
  • Advising on and conducting tax litigation;
  • Voluntary disclosure of undeclared tax liabilities;
  • Obtaining formal revenue clearances;
  • Dispute prevention;
  • Tax profile risk management; and
  • Reporting obligations.

Case studies

  • Family image

    Trusts should be both tax-efficient and cost-effective

    We helped a family tidy up a number of offshore trusts that had been operated over many years. We analysed the tax aspects of the trusts, their powers, and their investments. We then merged or wound up three trusts and recommended different distribution policies for different beneficiaries.

    The end result was a single substantial trust for each branch of the family: the trusts met beneficiaries’ long-term needs and were more tax-efficient, cheaper to run and better diversified.

  • Tax image

    Short-cuts can be expensive

    HMRC sought to prove that our client’s non-UK company was actually controlled from the UK by a UK resident shareholder – and should pay UK corporation tax.

    A few years earlier we had advised our client on this issue. We made it clear how important it was to follow decision-making procedures, to be able to evidence that the company was not controlled from the UK. The company had followed these procedures sufficiently accurately to enable us to refute HMRC’s claims.

  • Tax image

    A move to the UK needn’t mean tax problems

    We helped our Eastern European client make a tax-efficient move to the UK. First we advised him to bring some funds into the UK before he became resident.

    Then we helped structure his non-UK assets to deliver a tax-efficient flow of funds to the UK, setting up a suitable investment portfolio, and making sure that there was capital available to use in his ongoing business.

  • Property image

    Careful answers to a £70m property question

    We helped a wealthy Middle Eastern client structure a £70m portfolio of UK residential property.

    The solution included personal ownership for properties which the family would use, with a mix of debt and life insurance to minimise inheritance tax, and offshore structures for the rental properties. We keep a close eye on changes to residential property tax rules - so we can keep the structure up to date.

"I feel safe in the way things have been dealt with, covering all the aspects of one's legal needs."

Chambers UK 2016 – Private Client

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