Corporate Tax & Transactions

Group reorganisation, holding structures, financing, demergers, exits, share transactions and the tax aspects of business change.

The operating model was approved

October 16, 2026

The double-tax position had been reconciled. The next question was whether the group should keep defending it every year.

September 28, 2026

The UK permanent establishment existed. The next question was how much profit actually belonged to it.

August 12, 2026

Pillar Two has changed again: why the UK side-by-side Package is not the end of Global Minimum Tax

July 20, 2026

When a Tax Treaty Is Not a Loophole: What Burlington Means for Cross-Border Groups and Investors

May 18, 2026

Cross-Border Management Buy-Outs: The Tax Pressure Points founders and Management Teams must understand

May 1, 2026

The Cross-Border Demerger: when a Business needs a “divorce” before it can grow

April 26, 2026

Why Director’s Loan Accounts are becoming a bigger Tax Risk for SME owners

April 10, 2026

Why Dividend timing matters for SME owners

April 2, 2026

READY TO TAKE THE NEXT STEP?

Clearer Perspectives on Complex Tax

Technical commentary is only the starting point. Whether navigating complex HMRC enquiries or structuring international investments, Angelo Chirulli provides the high-level technical depth and strategic clarity required to deliver robust tax solutions.

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