Edwards Wildman Palmer UK LLP
Director of Tax, UK
Tel +44 (0)20 7556 4357
Fax +44 (0)20 7716 3747
Michael has a strong background in the tax aspects of all corporate, M&A and commercial work. He is a commercially minded tax practitioner with extensive experience in both UK and International tax matters. Specifically Michael specialises in corporate, finance and property taxation and has advised companies and institutions on a wide variety of matters. He has extensive experience with all aspects of corporate transactions including mergers and acquisitions, demergers and corporate reconstructions. He has also advised extensively on all aspects of property investment including stamp duty land tax, value added tax and capital allowances. Over the years, he has assisted a number of private equity houses in structuring and then implementing their transactions.
Prior to joining Edwards Wildman he was UK Head of Tax at the London office of another international law firm which had a substantial overseas presence. He is therefore fully conversant and familiar with the issues, structures and planning techniques that overseas investors need to adopt and implement in order to avoid unnecessary tax leakage in respect of their foreign investments. Specifically he has designed and implemented a number of structures which have utilised double taxation arrangements to facilitate the financing of overseas investments by non-UK resident investors so as to ensure that these investors can exit their investment without incurring any additional tax cost.
- Advising a UK plc on a proposed migration of their tax residency from the UK including the various means of migration and their consequences.
- Advising public sector and private sector participants in major regeneration projects across the UK including the use of joint ventures and tax incremental structures.
- Advising a major US listed company on the UK domestic and international tax implications of its proposed participation in a UK joint venture arrangement where all the other participants were also non-UK resident companies. The challenge was to maximise the tax deductions for the proposed development in the UK whilst ensuring that the Joint Venture participants could extract their equity and debt investment without incurring any unnecessary tax cost.
- Advising a UK listed company on its proposed participation in the construction and on-gong maintenance commitment in respect of a major infra-structure development in the Middle East. As domestic regulations required the involvement of a local contractor the development was undertaken via an offshore joint entity. From a tax perspective the objective was to ensure that the existence of the JV entity did not create any tax blockages for the UK listed company.
- Advising a French utility company on the tax implications of its proposed involvement in a joint venture arrangement with a local Indian company to undertake a development project in Mumbai. The planning was primarily concerned with the creation of a intermediate holding company in a third party jurisdiction to eliminate the Indian withholding taxes that would otherwise have arisen on the payment of interest, royalties and dividends.
- Advising the UK participants in a UK joint venture as to the appropriate structuring of the joint venture entity to maximise their tax relief entitlement.
- Advising UK investors as to the benefits of using a Luxembourg company for structuring investments into China and the Far East.
- Advising a major UK investment manager on the tax structuring and set-up of a Luxembourg holding company group for investments in European properties.
- Acting for a US group on the structure and set-up of an international fund for investment in East European real estate.
- Advising US shareholders in a UK listed company on techniques for implementing a tax efficient corporate restructuring in the UK and subsequent return of value to those shareholders.
- Advising UK investors on the most appropriate method for structuring a proposed inbound investment into India.
- Advising a management team on a secondary management buyout.
- Advising the management teams of private equity backed portfolio companies in respect of their incentivisation arrangements.
Recent Speaking Engagements and Publications
- "Tax, Technology and TV - Legal Developments in the Creative Sector", Edwards Wildman seminar, May 2013.