On M&A transactions a common requirement is the provision of specific tax liability insurance for the risk that a non-UK incorporated Target entity could be deemed to have been tax resident in the UK.
Continue reading “RESIDENCE”
A company seeks insurance for the risk that the loan relationship group continuity rules could apply to a transaction involving the novation of debt and a debt for equity swap.
Continue reading “LOAN RELATIONSHIP RULES & DEBT FOR EQUITY SWAPS”
Three individual sellers of their healthcare business seek insurance to obtain equality of tax treatment for the three individuals.
Continue reading “INDIVIDUAL SELLERS – CAPITAL GAINS TAX”
Tax liability insurance can help to facilitate the wind-up of a fund structure by providing insurance to cover the remaining, continuing liabilities of fund entities being wound up.
Continue reading “FUND STRUCTURE WIND UP”
Some Funds seek insurance for the risk that following the IPO of a portfolio entity, the distribution to investors could trigger a tax charge upon certain of the Fund’s investors.
Continue reading “DRY TAX CHARGE FOLLOWING DISTRIBUTION OF IPO PROCEEDS”
Whether a known potential tax liability has been identified during due diligence, or an uncertainty in the application of tax law that a client requires protection against, Tax Liability Insurance can provide the security you need. In the absence of agreement as to whom should take a known tax risk, tax liability insurance can help get the deal done.
Continue reading “AN INTRODUCTION TO TAX LIABILITY INSURANCE”