In any tax system, a high level of certainty is required for both ease of tax administration and the efficient collection of tax liabilities. Likewise, for companies and their stakeholders, domestic and international tax-related certainty is a fundamental goal. The UK’s EU referendum and potential exit from the European Union represent serious threats to this desired stability. And the biggest challenge businesses will face from a potential “Brexit” will be negotiating the resulting uncertainty.
There are many reasons to consider a carve-out transaction, from obtaining a cash infusion to introducing a new business line. But no matter what your motivation — or the size and age of your company — proper tax planning will allow you to better realize the full value of the business unit in question. Such transactions, which involve international elements and establishments in a number of jurisdictions, are particularly complex.