Rachel Palmer

Expertise

Rachel is a member of the tax team advising on a broad range of tax issues.

Rachel’s corporate experience includes advising on the tax aspects of acquisitions, disposals, reorganisations and investments, acting for corporates, individuals, financial institutions and private equity houses. Rachel frequently drafts and negotiates the tax provisions in share purchase agreements, including deals involving warranty and indemnity insurance, and business purchase agreements, particularly in the context of transfers of a going concern.

Rachel advises clients on the design and implementation of a wide variety of share and cash-based employee incentive arrangements including EMI, CSOP, SIP, unapproved options and cash-bonus schemes.

Rachel frequently advises clients, including national housing developers, on the SDLT and VAT implications of acquisitions of property for development, including being involved in drafting applications for SDLT relief and advising on the deferral of SDLT. Rachel has experience advising on residential SDLT including the categorisation of land as residential or non-residential, the 3% surcharge for higher rates transactions, the 2% surcharge for non-resident transactions and the 15% SDLT rate for high-value residential transactions.

Experience

1. Providing tax structuring advice to shareholders on a pre-sale reorganisation of a corporate group and an ultimate sale to a third party.
2. Advising a non-UK listed company on the tax aspects of its acquisition of an international corporate group.
3. Acting for a private equity firm on the tax aspects of its investment into a global digital transformation services provider.
4. Implementing and advising on a share incentive plan (SIP) and a long term incentive plan (LTIP) for a listed company.
5. Providing stamp duty and SDLT advice on the reorganisation of a large property investment group.
6. Advising three national housebuilders on the SDLT and VAT implications of their disposal of a major development site.