Zoe Feller
I am a tax lawyer specialising in corporate, asset finance and structured finance transactions.
I have particular strength advising on the tax aspects of international matters, often coordinating teams across multiple jurisdictions.
I work with clients setting up in the UK and EU, working seamlessly with colleagues across our network to help clients identify the unique challenges that each jurisdiction presents and putting in place the most effective business model to ensure their brand will thrive.
Tax law has changed significantly over the last few years with the emphasis on international coordination to eliminate tax evasion and ensure profits are taxed where they arise through the OECD and G20 nations' BEPS project. I advise clients on the impacts of these changes which have been introduced both at an international and domestic level. The new multilateral instrument has amended double tax treaties and changed the way businesses borrow money, lease assets, distribute profits and hold IP - this affects all of our clients with cross border businesses, including asset leasing, franchising, IP rich digital businesses and financial services clients. The UK has also implemented BEPS related changes on which I regularly advise, such as the digital services tax and the interest restriction rules.
2 Contributions by Zoe Feller
PRACTICE NOTES
UK corporate demergers: statutory, capital reduction and liquidation routes, pre‑demerger restructuring and HMRC clearances: key tax reliefs, risks and stamp taxes
A demerger is the division of a company’s business into two or more segments, usually continued by successor entities that remain under the original ownership.
Typical commercial reasons include:
splitting a business ahead of a sale or other deal
bringing in different shareholders (or option holders) to one venture but not another
separating activities with differing risk, regulatory or commercial profiles
resolving a shareholder dispute
releasing value from an underlying business
carving out a non-core activity as the group matures, or
using a demerger as an alternative to a sale
There may also be tax advantages, for example:
investment businesses can be split from trading businesses so trading businesses can qualify for:
business asset disposal relief (formerly entrepreneurs' relief)
the substantial shareholdings exemption, or
inheritance tax business property relief, see Practice Note: IHT—business property relief
, and
the proceeds of any sale of a demerged business are realised directly by shareholders, so any gain may qualify for business asset disposal relief
However, if tax is the sole reason for a demerger, the various commercial purpose tests are...
Tax
PRACTICE NOTES
UK tax implications for cross-border joint ventures: structuring, asset transfers, financing (debt/equity), withholding taxes, CFCs, hybrid mismatches, loss relief, profit extraction and exit
This Practice Note
This Practice Note examines the principal tax considerations that arise when setting up, managing and winding up an international joint venture, in addition to those encountered with a domestic UK joint venture...
For guidance on the UK tax aspects of domestic joint ventures, refer to the following Practice Notes:
Tax implications of contractual joint ventures
Tax implications of establishing a joint venture partnership
Tax implications of operating and terminating a joint venture partnership
Tax implications of establishing a joint venture company
Tax implications of operating and terminating a joint venture company
For this Practice Note, an international joint venture is treated as an arrangement where either the joint venture vehicle (if there is one) or at least one joint venture party is not UK tax resident. It is assumed throughout that the joint venture participants are corporate entities...
For information on the corporate aspects of international joint ventures, see Practice Note: Cross-border joint ventures—overview...
Tax
If you expected to see yourself on this page, click here.
