Corporate tax in Scotland

Brodies LLP

Brodies LLP’s specialist corporate tax team provides tailored advice to clients throughout the Scottish market. The team acts for high-net-worth individuals and family businesses, and is particularly experienced in real estate transaction tax structuring and high-value corporate transactions, often with an international aspect. Isobel D’Inverno heads the practice and is well known in the market for her extensive knowledge of land and buildings transaction tax (LBTT) and stamp duty land tax (SDLT). Alan Barr is recommended for business and personal tax matters, and senior associate Heather Gibson handles the tax aspects of M&A transactions.

Practice head(s):

Isobel d’Inverno

Other key lawyers:

Heather Gibson; Bob Langridge; Alan Barr; Karen Davidson; Heather Thompson

Testimonials

‘Approachable, pragmatic and commercial team.’

‘They cover a broad range of tax work and have strength in depth.’

‘Helpful attitude and commercial approach.’

‘Approachable, pragmatic and commercial individuals.’

‘Bob Langridge is excellent. He is technically very good but manages to convey quite complex issues in a clear and succinct manner. We have complete confidence in them and would always recommend them for any more complex tax issues.’

‘Positive approach and timely advice – Isobel d’Inverno is very helpful.’

Key clients

LCN

Drum Property Group

Apache Capital Partners

Borr Drilling Group

Simec Group

DC Thomson & Co Ltd

Kanam

Knight Frank Investment Management Limited

Abellio

Soller Real Estate

Work highlights

  • Advised a Korean real estate fund on the acquisition through a Jersey Property Unit Trust structure of the Jersey based company owning the Amazon fulfilment facility at Dunfermline, Fife.
  • Advised Gresham House plc on the structuring and set up of a fund (with initial investment of c. £105m) to invest in the New Zealand emissions trading scheme.
  • Advised the shareholders of ECS Digital Limited, ECS Europe Limited and ECS Global Ltd on the tax aspects of the disposal of the ECS group of companies to GlobalLogic Inc, providing both tax and share incentives advice across a group of circa 70 shareholders.

Dentons

As part of the wider firm's UK practice, Dentons' Scottish tax team handles high-profile tax matters in Scotland and internationally. It is well placed to handle cross-border advisory and transactional work, and advises on tax issues concerning employees working remotely overseas. Glasgow’s Gwen Souter is a chartered accountant, who heads the team alongside the London-based Alex Thomas. Lorna McCaa is a member of the Tax Committee of the Law Society of Scotland and the Property Tax Committee of the Scottish Property Federation, and has considerable experience in handling the tax aspects of real estate and corporate transactions. Roddy Harrison left for Wright, Johnston & Mackenzie LLP in January 2021.

Practice head(s):

Gwen Souter; Alex Thomas

Other key lawyers:

Lorna McCaa; Alastair MacLeod

Testimonials

‘The team is made up of high quality people, with a good knowledge of business’.

‘Although it is a large firm, the relationship felt personal’.

‘Very approachable, responsive, friendly and confidence-inspiring’.

‘Lorna McCaa handled complicated tax matters but was patient and helpful in managing the situation with company directors in offering solutions, explanations and resolutions of issues arising’.

Key clients

M&G Real Estate (various funds)

The PRS REIT plc

The Edrington Group Limited

Hansa Trust plc

Hurricane Energy plc

Scottish Equity Partners LLP

The Valence Group

J Sainsbury plc

John Lewis Partnership

Charles Ritchie’s Testamentary Trust

Work highlights

  • Acted for Charles Ritchie’s Testamentary Trust as 96% shareholder and principal vendor of the entire issued share capital of Score Group plc.
  • Advised DB Financial Investment Co. Ltd on the acquisition of 1-3 Lochside Crescent, Edinburgh, an office complex that acts as Aegon’s UK headquarters for South Korean investors.
  • Instructed by Murray Income Trust plc in relation to its combination with Perpetual Income & Growth Investment Trust plc (PLI).

Burness Paull LLP

The tax team at Burness Paull LLP offers a broad range of expertise, with corporate finance-related tax matters, and private equity and management incentives being key areas of focus. The team also handles real estate-related tax matters across all asset classes, including LBTT and SDLT. It often acts for family and owner-managed businesses (OMBs) on employment tax issues, and also caters to the personal tax matters of individuals. Head of practice Ronnie Brown often advises London firms and is well versed in transactional tax matters. Claire Macpherson was promoted to partner at the start of 2021.

Practice head(s):

Ronnie Brown

Other key lawyers:

Gary Chapman; John Finnick; Robert Burns

Testimonials

‘Ronnie Brown is approachable and able to describe difficult tax matters well’.

‘Responsive and commercially focused’.

‘I have built up an excellent relationship with Ronnie Brown, one of their senior partners, over the last 25 years; his team is very good’.

Key clients

Management of Total Mobile Limited

Management of Connexas

Murgitroyd Group PLC

London & Scottish Investments

i3 Energy plc

Calnex PLC

Scottish Power PLC

Sword Charteris Limited

Work highlights

  • Advised Cemex in connection with Scottish tax issues involved in the sale of Cemex’s Scottish assets to Breedon Group for £178m.
  • Advised the managers of Learning Curve Group Ltd in connection with the buyout of LCG from their PE sponsor, MML Capital, by Agilitas, a pan-European mid-market private equity firm.
  • Acted for Wernick Power Solutions Limited in the acquisition of Power-Rite (UK) Limited, a specialist generator rental and maintenance provider.

MacRoberts LLP

The dedicated corporate tax practice at MacRoberts LLP is led by chartered tax adviser Ainsley MacLaren, who has over 25 years’ experience in the industry and sits on the Law Society of Scotland’s Tax Sub-Committee and the Tax Committee of the Scottish Property Federation. Areas of focus include M&A-related tax, VAT and SDLT/LBTT around property transactions, and tax planning advice for shareholders.

Practice head(s):

Ainsley Maclaren

Key clients

BAM Properties

Brookfield Renewables (UK) Limited

Breedon Aggregates plc

Chivas Brothers (Pernod Ricard group)

Renaissance Care (Scotland) Limited

Robertson Property Limited and Live Nation Entertainment

Scottish Government

Tillicoultry Quarries Limited

Together Energy Limited

Wm Morrison Supermarkets PLC

Work highlights

  • Advising on the land transaction tax aspects of a bid by Robertson Property Limited and Live Nation Entertainment Inc to develop and operate a new 15,000 seater indoor arena at Atlantic Wharf, Cardiff in conjunction with Cardiff City Council at a cost of approximately £150m.
  • Advised Breedon Group plc on the provision of land and buildings transaction tax advice in relation to the Scottish properties acquired as part of the acquisition of the assets and operations from CEMEX UK Operations Limited.
  • Advised the shareholders of AGL Wealth Management Ltd on the provision of transaction tax advice to the shareholders of AGL Wealth Management Ltd on the sale of the entire issued share capital to IWP Newco 1 Limited, a subsidiary of Independent Wealth Planners UK Limited (IWP).

Shepherd and Wedderburn

Shepherd and Wedderburn is well regarded for its knowledge of LBTT and SDLT, and also VAT planning. Other areas of expertise include corporate transaction tax, bespoke tax for individuals, and specialist tax advice for individual shareholders, including entrepreneurs’ relief from capital gains tax and income tax planning. The team is co-headed by Rodger Cairns and Stephen Miller, who is a chartered tax adviser with expertise in tax aspects of corporate acquisitions, disposals and restructuring, and real estate and property development.

Practice head(s):

Stephen Miller; Rodger Cairns

Other key lawyers:

Douglas Sinclair

Testimonials

‘They are very knowledgeable and can cut through complexity to provide solid legal advice’.

Key clients

Epic Games Inc

Bigblu Broadband PLC

Cairn Energy plc

Taylor Wimpey UK Limited

BAE Systems

EE Limited

Miller Homes Limited

Tilstone/Warehouse REIT

Hermes

British Land PLC

Work highlights

  • Advised Epic Games on the tax aspects of its acquisitions of Cubic Motion and SuperAwesome.
  • Advised Cairn Energy PLC on the tax aspects of the sale of an interest in offshore Senegal oil fields to LUKOIL Upstream Senegal B.V.
  • Advised AIM-listed Bigblu Broadband PLC on the tax aspects of the sale of its European and UK satellite broadband business to Eutelsat SA.

DWF

DWF’s Scottish tax offering sits within the wider UK team and services a wide range of clients, from SMEs to blue chip companies. The Scottish team is working increasingly closely with its counterparts in Europe to cater to post-Brexit tax issues. It handles M&A and private equity-related tax matters and is headed up by Jon Stevens in Birmingham. Caroline Colliston is the key name in Scotland.

Practice head(s):

Jon Stevens

Other key lawyers:

Caroline Colliston

Key clients

Element Materials Technology Group Limited

Wm Morrison Supermarkets Plc

Lunar JV Finance (Apollo Asset Management Group)

Marks & Spencer plc

Mowi Scotland Limited (formerly Marine Harvest)

Capita plc

Custodian REIT plc

Mattioli Woods plc

Event Scotland

Visit Scotland

Costa Coffee

Zonal Retail Data Systems

Grahams the Family Dairy

Aliter Capital LLP

Sponge Group

LDC

Cirrus Response Group Limited

Ambassador LB Holdings Limited

Ipsum Group Limited

Edwin James Group Limited

Swan Group plc

Glennon Brothers Timber Limited

Sterling Furniture Group

Perle Hotels

Martley NAH Limited

Work highlights

  • Providing share scheme and tax advice in relation to the exercise of options in relation to the sale of stock imagery specialist, Alamy to PA Media Group for an undisclosed sum in February 2020.
  • Providing tax transactional support in acting for Element on its acquisition of EnviroDat Limited (an industry leading UKAS and MCERTS accredited environmental testing provider).
  • Providing specialist Scottish land transaction tax advice to a wide range of real estate clients including Marks & Spencer, Costa, WH Smith, BT plc and others.

Pinsent Masons LLP

Pinsent Masons LLP acts for FTSE 100 companies, institutional investors, entrepreneurs and government bodies on a broad range of corporate tax matters. The Glasgow-based Christine Yuill is the key name in Scotland; has considerable experience in the tax aspects of M&A, joint ventures, reorganisations and property tax issues, such as VAT, SDLT and LBTT.

Practice head(s):

Christine Yuill

Testimonials

‘Repeated high quality advice’.

‘The Pinsents team get to the answer quickly and provide the right level of detail to allow you to get on with your business without wading through lots of legal jargon’.

‘Christine Yuill has an impressive blend of traditional corporate knowledge and specialist tax knowledge’.

‘Everyone was always friendly and clear and I received responses in a good time frame’.

‘Christine Yuill brings her experience to the table each time, highlighting and addressing potential issues and factors you didn’t know were even there’. 

‘Christine Yuill was great at assessing the needs prior to quoting for the work and was happy to provide further explanation of clauses’.

Key clients

Total E&P Limited

Zenobe Energy Limited

iomart Group plc

Railway Pensions Investment Limited

Energetical Limited

Beeks Financial Cloud Group plc

Red Rock Power Limited

Resonance British Wind Energy Income II

M Group Services Limited

Induction Healthcare Group Plc

Online Education Services Pty Ltd

Jersey Oil & Gas plc

Piper Private Equity

Nevis Capital LLP

CALA Group

Work highlights

  • Provided tax structuring advice to Zenobe Energy Limited on a £150m investment from an acquisition vehicle established by Infracapital Funds.
  • Advised oil super major Total on its disposal of UK North Sea non-core assets to a subsidiary of NEO Energy, a vehicle backed by Norway-based private equity investor HitecVision.
  • Provided tax structuring and share incentives advice to Piper Private Equity on its £11.5m investment in to Wattbike, the indoor exercise bike brand.