International Entrepreneur - Personal Restructuring

International Tax | Wealth Structuring

An international entrepreneur with business interests across multiple jurisdictions approached us for advice on rationalising their personal and corporate structures.

The client was originally from overseas but had become UK resident several years earlier.

They held interests in companies in the UK, UAE, and several other jurisdictions, as well as property in multiple countries. The existing arrangements had become complex, inefficient, and difficult to manage.

The client's objectives were to simplify their affairs, ensure compliance with UK tax obligations, and optimise the overall tax position where legitimately possible.

We began by mapping the existing structure, which revealed significant complexity:

• The client held interests in over a dozen companies across five jurisdictions, some of which were dormant or no longer served any purpose.
• Property was held through a mix of personal ownership, corporate ownership, and trust arrangements, with no consistent rationale.
• Intercompany arrangements were in place but had not been updated for several years and did not reflect the current commercial relationships.
• The client's UK tax returns had been prepared on a somewhat ad hoc basis, and there were potential areas of exposure.

We prepared a comprehensive restructuring plan addressing each of these issues:

• Corporate Simplification: We identified companies that could be liquidated, merged, or struck off, reducing the administrative burden and ongoing compliance costs. We advised on the tax implications of each step and the availability of reliefs.
• Property Rationalisation: We reviewed the ownership of each property and advised on whether the current structure was appropriate. In some cases, we recommended transferring properties between entities to achieve a more efficient outcome.
• UAE Structures: The client had established UAE entities that were not being used optimally. We advised on how these could be integrated into the overall structure to achieve genuine commercial benefits.
• Intercompany Arrangements: We reviewed the existing arrangements and advised on updates required to ensure they were arm's length and properly documented.
• UK Compliance: We reviewed the client's UK tax position and identified areas where additional disclosure or amendment might be required.

The restructuring was implemented over approximately twelve months, with close coordination between advisers in multiple jurisdictions. We prepared detailed implementation steps and monitored progress throughout.

Outcome

Comprehensive personal restructuring completed over twelve months. Corporate structure simplified from twelve entities to six, property holdings rationalised, intercompany arrangements updated, and UK compliance position confirmed.

This case study is based on a real client matter. All identifying details have been removed or changed to protect client confidentiality.