Eerik Kukebal advises on a wide range of tax issues with a particular expertise in cross-border transactions, VAT, M&A and corporate reorganisations. He has experience in advising on tax planning structures for property development, employee share incentive plans and joint venture and collaboration arrangements.
Eerik provides Tax advice in relation to corporate restructurings, debt reorganisations, share incentive plans and partnership incorporation transactions. In addition, Eerik also advises on cross-border transactions, reverse charge VAT, withholding tax, transfer priding, double taxation treaty reliefs, personal tax advice on tax residence, international employment taxes, taxation of UK permanent establishments and Diverted Profits Tax.
- Advising on the availability of a double taxation treaty (DTT) relief under the UK / Germany DTT and securing the relief from UK withholding tax on the payment of interest by a UK LLP to its German designated members.
- Tax and SDLT advice in connection with the incorporation of a property holding partnership.
- Tax advice on the acquisition by a US buyer of a US company with a UK business – existence of a UK permanent establishment and associated tax risks assessment.
- Advising on the reorganisation of a corporate group holding a high-profile residential London property portfolio to achieve a more streamlined group structure in preparation for a refinance of the group’s existing bank facility of £43m.
- Implementation of a nil-paid share incentive plan for an M&A advisory business.
- Advising on a migration and incorporation of a UK partnership in another jurisdiction in the EU to take advantage of an Intellectual Property Box regime and advice on transfer pricing and Controlled Foreign Companies regime.
- Incorporation of a business of a YouTube content provider.
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