From our London office at Holborn Gate, 330 High Holborn, WC1V 7QH, we advise UK and international clients on the interaction between tax, pensions, employment law and incentive arrangements. The issues are often intertwined: tax-efficient reward design must respect employment law and pensions regulation; restructurings need coordinated tax and HR planning; and cross-border mobility raises withholding, reporting and social security questions.

Strategic tax advice and cross-border considerations

We provide transactional and ongoing tax advice covering corporate tax, employee taxation, transfer pricing, withholding obligations and cross-border mobility. Key considerations include:

• Structuring remuneration and exit packages to manage income tax, national insurance and employer charge exposure under UK rules (including considerations for off-payroll working and intermediaries).
• Cross-border secondments: residency, double tax treaty relief, social security and payroll obligations where employees work across jurisdictions.
• Tax controversy and disclosure: managing HMRC enquiries, settlement negotiations and reasonable care in reporting arrangements.

Pensions: scheme design, funding and trustee duties

Pensions issues cut across corporate balance sheets, employee relations and regulatory risk. Our work covers:

• Auto-enrolment compliance and employer contribution obligations under England and Wales law.
• Work with trustees on covenant assessment, funding negotiations, schedule of contributions and de-risking transactions such as buy-ins and buy-outs.
• Advising on trustee fiduciary duties, governance, conflicts and regulatory interaction with The Pensions Regulator.

Employment law and incentive structures

Practical employment law advice ensures incentive arrangements are enforceable and compliant. Typical areas of focus:

• Design and documentation of equity and cash-based incentive plans (EMI, SAYE, CSOP-style structures and bespoke arrangements), with attention to tax-efficient features and HMRC conditions.
• Contracts, restrictive covenants and post-termination arrangements: drafting to withstand challenge while balancing commercial needs.
• Collective issues: TUPE in restructurings, collective consultation obligations, discrimination risk and tribunal exposure.

Practical checklist

1. Map all stakeholders: employees, executives, trustees, payroll and tax teams.
2. Confirm residency, employment status and social security position for cross-border assignees.
3. Review incentive plan rules against HMRC tax relief conditions and employment contract terms.
4. Assess trustee obligations, scheme funding position and need for covenant support before corporate transactions.
5. Implement documentation and compliance filings—payroll reporting, P11D, PAYE, auto-enrolment and any necessary disclosures to regulators.

Jurisdiction and sources

Primary sources for England and Wales matters include HM Revenue & Customs (HMRC), GOV.UK guidance, The Pensions Regulator, HM Treasury, Companies House and Acas. For international tax standards and treaty matters consult the OECD guidance and relevant double tax treaties.

We adopt an integrated approach: aligning tax structuring, pensions governance and employment documentation reduces regulatory risk and supports commercial objectives. Where matters cross UK borders, early co-ordination with local counsel and tax advisers is essential to avoid unintended withholding, social security or benefits exposure.

General information only; not legal advice and not a substitute for advice on a particular matter.