Company A Group Limited was looking to sell off two subsidiaries to an overseas buyer in exchange for shares. With the structure the client had in place, the sale of the two companies would have resulted in a tax liability of around £1.8 million on a paper gain and also caused the shareholders to lose favoured tax status.

Comment: MTG devised a group reorganisation which resulted in the two companies being sold with no immediate tax liability to the group or its shareholders.

Company B Limited wished to reward and tie in employees. Bonus schemes were expensive and arbitrary and caused cash constraints.

Comment: MTG recommended, and went on to implement a tax efficient share arrangement. This achieved the client’s objectives and also gave the founder shareholders the opportunity to establish an alternative exit strategy.

Company C Limited had a very complex group structure comprising of a number of non trading intermediate holding companies which served no purpose. ‘C’ was the ultimate parent company of a company which had a number of divisions. The share structure had arisen as a result of a number of acquisitions and shareholder changes which was administratively difficult to manage.

One of the divisions, ‘A’ was subject to negotiations for a separate joint venture with a US owned company. The structure was not conducive to establishing joint venture arrangements, nor to achieving a successful transaction with the potential US owned purchasers, and indeed the complexity of the structure caused the potential purchaser to reconsider their position.

Comment: A tax efficient group reorganisation was implemented to give the ultimate shareholders direct control of the ‘A’ division enabling the joint venture to proceed.

Christmas Decorations Limited (CDL) held two subsidiaries, Shabby decorations and Elf Merchants Limited. Shabby Decorations was dormant. Elf Merchants Limited had become an investment company holding a property which was used outside the business. Christmas Decorations Limited used its property inside the business.

The shareholders wanted to plan an exit from the business but retain the property.

Comment: MTG separated the property and the trading activity into two stand alone companies without incurring a tax charge. This then set the stage to enable a structured exit from the trading activity which could be achieved by a direct sale to a third party, undertaking a management buy out, or by passing the business to the next generation.