Tax - M&A & Joint Ventures

Many of these transactions have involved the restructuring of the international group and tax issues in jurisdictions other than those of the target or parent. Linklaters combines tax expertise in each jurisdiction into one team to resolve different tax and structural issues, without losing sight of the commercial framework of the transaction.

In major M&A transactions and joint ventures, Linklaters fully integrates the tax aspects of the deal with the other legal and commercial considerations. Where there is a conflict between tax and regulatory considerations, for example, the team has the experience to spot that conflict and the expertise to provide a workable solution.

In cross-border tax planning, specialist lawyers in Linklaters’ global tax team are ideally placed to help leading corporates and financial institutions to structure a deal so as to enhance tax efficiency.

Recent M&A and joint venture transactions include advising:

  • Citibank on the sale of its German retail banking business to Crédit Mutuel
  • Lloyds TSB on its recommended acquisition of HBOS by Scheme of Arrangement and the contemporaneous placing and open offer of Lloyds TSB equity and preference share capital, fully underwritten by HM Treasury
  • in relation to the UK tax aspects of the acquisition of Porterbrook Leasing Company Limited (one of the UK's train leasing companies) from Abbey National by a largely debt financed bidding consortium including Deutsche Bank and Lloyds TSB as majority investors
  • Centrica on their joint venture with EDF
  • the consortium bid by RBS, Fortis and Santander for ABN AMRO and on the subsequent break-up of the ABN AMRO group between the consortium members
  • on the demerger of Mondi from Anglo American plc and listing of Mondi on the LSE and the JSE by way of dual listed company structure
  • on the demerger which split GUS into Home Retail Group (Argos and Homebase) and Experian
  • on the acquisition and cross-border merger of SachenLB Plc into Landesbank Baden-Württemberg
  • Magnum Capital and other co-investors on the €1.15 billion acquisition of all operating wind farms held by Babcock & Brown in Portugal (a total of 515MW) as well as several other wind farms under construction (156 MW). This deal was the largest ever private equity-led investment in Portugal and the largest wind asset acquisition by a private company in Europe