Corporate tax in Scotland

Brodies LLP

Brodies LLP fields a team of dedicated, full-time tax specialists who advise across an array of real estate and corporate transactions in addition to related disputes. Isobel D’Inverno fronts the practice and is particularly knowledgeable of both Land and Buildings Transaction Tax (LBTT) and Stamp Duty Land Tax (SDLT) and is particularly well placed to support on the structuring of inward investments; she regularly serves as advisor to the Scottish Government and Revenue Scotland alongside Alan Barr, an authority on the full array of personal and business tax matters. Other standout names include Karen Davidson, an expert in respect of the private equity and corporate transactions, as well as senior associate Heather Gibson who often advises overseas corporates on arising tax responsibilities.

Practice head(s):

Isobel d’Inverno

Other key lawyers:

Alan Barr; Karen Davidson; Heather Gibson; Heather Thompson

Testimonials

‘We work primarily with Karen Davidson. She is a strong all round tax lawyer, which a particular strength in employment taxes. She is responsive and a very strong technical lawyer who is a pleasure to work with.’

‘Brodies know our funds, clients and assets well and have worked with us over many years. They are also able to bring new developments to our attention and inform us of any opportunities or implications which may arise.’

‘We work with Isobel D’Inverno and the team – the deep sector and client knowledge makes them invaluable.’

‘Isobel d’Inverno is a partner with a deep knowledge of her area and supported by a team who clearly likewise know their subject who worked well with our other legal advisors on a particularly technical piece of advice.’

‘The answers given are clear and concise and not caveated.’

‘We liaise with Brodies on a regular basis in relation to employment and tax advice. The team are always very approachable and respond within agreed timescales. The advice is always delivered at an appropriate level. Expertise in a range of areas – while our requirements tend to focus on certain areas the solicitors are able to direct to other colleagues when required.’

‘We mostly work with Heather Gibson in the Tax team. Heather is always approachable and friendly, she has developed a good understanding of our organisation and tailors her advice accordingly. Any advice provided is delivered at an appropriate level – usable for non tax experts. Agreed timescales for work are always met.’

Key clients

Accel-KKR

Bristow Group

Borderlink Broadband Limited

TPG Europe LLP

Mirador Analytics Limited

BAE Pension Trustees

AGS Airports

Northcare Group

Orion

Gresham House

Work highlights

  • Instructed by BAE Systems to purchase the WaveGarden Scotland from Tartan Leisure Limited on a sale and leaseback basis.
  • Instructed by Gresham House to establish a new woodland fund aimed at generating voluntary carbon credits under the UK Woodland Carbon Code.
  • Advised the shareholders of Mirador on their tax position in relation to the acquisition of the company by US based Datavant group.

Dentons

Dentons calls upon its extensive international footprint to support clients on a broad variety of domestic and international tax matters; examples include the planning and structuring of corporate transactions and reorganisations, employment taxation and share schemes, real estate tax, cross-border deals and VAT. Gwen Souter, the team’s practice head, is also a charted accountant and caters to a mixture of listed companies, multinational entities and privately held businesses; her team includes Lorna McCaa, dual-qualified as a charted tax adviser, whose expertise spans corporate and property transactions, tax-efficient employee incentivisation schemes, SDLT, LBTT and capital allowances.

Practice head(s):

Gwen Souter

Other key lawyers:

Lorna McCaa; John Finnick

Key clients

M&G Real Estate (various funds)

The PRS REIT  plc

The Edrington Group Limited

Axle Group Holdings Limited

Hurricane Energy plc

Scottish Equity Partners LLP

Bute Island Foods Limited (and its shareholders)

Evolution Equity Partners

John Lewis Partnership

Marshall Motor Group Limited

Work highlights

  • Providing a full range of tax advice to Sigma Capital Group plc in relation to a £188m recommended all cash offer for its entire issued and to be issued ordinary share capital by Six Bidco Ltd, a wholly-owned indirect subsidiary of investment funds managed by PineBridge Benson Elliot LLP.            
  • Advising Evolution Equity Partners as Lead Investor on Elliptic’s $60m Series C funding round.  Elliptic’s business of cryptoasset risk management meets demand for a product that did not exist in any material way until recently.
  • Acted for the shareholder sellers of Bute Island Foods Limited who founded and built the business, a leading producer of vegan cheese, to a Canadian multi-national.  This was a significant and high value transaction for an area of Scotland outside the main population centres.

Burness Paull LLP

Burness Paull LLP operates across a broad variety of mandates including the tax aspects of corporate, real estate, private equity and international transactions. Ronnie Brown heads the practice and notably serves as advisor to a number of accountancy and law firms in both London and Scotland, especially in respect of LBTT; his team is also geared to support owner-managed businesses (OMBs) and individuals and routinely advises on employment-related tax matters, recently serving a number of public and private sector clients on the new off-payroll working rules. Director Nicola Williams is a new arrival from Dickson Minto WS and joins with a track record in advising on the tax aspects of share schemes, M&A, angel investment and private equity.  

Practice head(s):

Ronnie Brown

Other key lawyers:

Claire Macpherson; Nicola Williams

Testimonials

‘Burness Paull are always approachable, responsive and willing to take the time to explain and ensure that you understand the situation fully.’

‘Everyone at Burness Paull represents the firm to the highest standards.’

Key clients

The Royal London Mutual Insurance Society Limited

Access UK Ltd

Maven Capital

Kings Park Capital

Brookfield Renewable UK Limited (“BRUK”)

Lonsdale Capital Partners L.P.

Kester Capital

UPM-Kymmene Oyj

Cruden Homes

London & Scottish Property Investment Management

Savannah Energy PLC

Work highlights

  • Advised London based private equity firm Lonsdale Capital Partners L.P. in the sale of Cross Rental Services. The team provided general tax advisory services in relation to the sale, including negotiation of tax indemnities and warranties.
  • Advising a Finnish listed company (UPM-Kymmene Oyj) on the disposal of a UK-based asset to a buyer based in Turkey. The group provided detailed tax structuring and transactional advice.
  • Providing tax advice to Access UK Ltd in relation to their ongoing expansion.

MacRoberts LLP

At MacRoberts LLP, the team delivers transactional tax advice to both corporate entities and individuals, acting on matters such as property-related VAT, land and buildings transaction tax, tax-efficient structuring, the off payroll working rules and employment-related tax. Ainsley MacLaren heads the practice, leveraging over 25 years of dedicated tax work at both legal and accounting practices; her expertise spans VAT, share schemes and cash-based incentives, SDLT and buildings transaction tax.

Practice head(s):

Ainsley MacLaren

Key clients

Breedon Aggregates plc

J & J Denholm Limited

Menzies Distribution Limited

Renaissance Care (Scotland) Limited

Scottish Government

Scottish Power Transmission

Scottish Salmon Company

Student Loans Company

Tillicoultry Quarries Limited

Wm Morrison Supermarkets plc

Work highlights

  • Provision of advice in relation to the tax warranties and tax indemnities in relation to the sale of shares in Sutherland Independent Limited and Buchanan & Associates Financial Planning Limited to IWP as it continues its consolidation in the financial planning market.
  • Acting for Tillicoultry Quarries Limited on the provision of VAT and land and buildings transaction tax advice in relation to the acquisition of 4 concrete plants in Scotland by Tillicoultry Quarries from CEMEX UK. This deal was a key strategic acquisition for Tillicoultry Quarries’ in broadening its geographic reach for ready mixed concrete products. The deal follows on from the acquisition by Tillicoultry Quarries of 14 new sites from BreedonAggregates in November 2020.
  • Acting for the shareholders of JBB Ground Care Limited in relation to the sale of their shares to Nurture Landscapes Holdings Limited, providing advice on tax warranties and tax indemnities and other transaction-related tax matters.

Shepherd and Wedderburn

Services provided by Shepherd and Wedderburn include corporate transaction, real estate, share scheme, LBTT, SDLT, capital gains and income tax planning advice. Stephen Miller is particularly accomplished in terms of corporate acquisitions, disposals and restructuring in addition to property transactions and developments meanwhile Douglas Sinclair is a go-to for stamp duty compliance, venture capital relief and business disposals; both are charted tax advisers and members of the Charted Institute of Taxation.

Practice head(s):

Stephen Miller; Rodger Cairns

Other key lawyers:

Douglas Sinclair

Key clients

Well known US-based gaming company

Major UK housebuilding firm

Well known UK telecoms company

Well known food retail business

Established fish farming company

Major investment bank

Well known trading company

Asset management company

Large listed telecoms company

Work highlights

  • Advised a leading US gaming company on the tax aspects of its acquisition of a UK-based games developer and two gaming development houses.
  • Advised a client on the tax aspects of the Initial Public Offering of a fast-growing client in the food retail sector, including a pre-IPO restructuring.
  • Advised a leading investment bank on the tax aspects of funding the development of four purpose built student accommodation schemes.