A financial institution undertook an intra-group restructuring where it would only be prepared to conduct such restructuring if it did not lead to significant tax charges.

Various issues were identified on the merger and we were able to insure them all. The main underwriting focus was on the tax neutrality of the merger which would have led to a significant tax charge if not undertaken correctly and for the right motives.

We worked with the institution’s head of tax and external tax advisors and issued a policy for each of the identified risks which provided the certainty the client required.