Tom has more than 30 years of experience as a tax lawyer, focusing on business tax matters and acting for a broad range of clients, ranging from entrepreneurs and management teams to private equity houses, large PLCs/multi-nationals and financial institutions.
The range of his practice includes advice to start-up and early stage businesses, often in the context of obtaining tax efficient funding from investors (securing related HMRC pre-investment approvals), advice on corporate restructuring (and associated HMRC clearances), on the structuring and implementation of company sales/acquisitions and on employment tax matters, include bespoke equity incentive arrangements. He also advises on the tax aspects of commercial and financing projects, often involving an international dimension.
- Structuring M&A and business/asset sale transactions
- Tax indemnities/ warranties and other transaction documentation
- Advising owner/managers: Structures for business ventures and exit planning
- Tax efficient funding for start-upand early stage businesses: seed and enterprise investment schemes;securing advance assurances from HMRC
- Corporate reorganisations, demergers
- Tax aspects of P2P lending
- Commercial structures and projects: joint ventures, franchising, IP licensing, PFI/PPP projects
- Employment status issues; personal service companies; agency rules
- Termination packages
- Share incentive plans and bespoke equity incentive arrangements; enterprise management incentive options
- Cross-border transactions,structures and projects
- Double taxation relief, withholding taxes, transfer pricing
- Entity classification issues
- Cross-border assignments of employees
- Advising Virgin Group on a reorganisation and disposal involving its Brussels based low cost airlineoperation, including arrangements for the distribution of the proceeds of the disposal and the de-listing of the parent company.
- Advising Adidas on tax issues relating to its acquisition of Reebok. Comment to Tom Daltry by US lawyer involved on the transaction: “Your responsiveness and professionalism were much appreciated, especially given the time constraints involved. And,most importantly, the advice you provided was just what we needed.”
- US/UK transactions have included advice to Doubleclick Inc on a disposal of subsidiaries and repatriation of proceeds of sale; advice to Brinks Inc on a UK acquisition and subsequent corporate reorganisation; advice on numerous structures involving hybrid US entities such as LLCs.
- Advising a bank on the structure for its acquisition of a high street retailer’s store card receivables and related arrangements for the launch of a credit card, including VAT advice on services agreements between the parties involved (a transaction involving acquisition, joint venture and outsourcing elements).
- Bespoke equity incentive arrangements for senior employees in private companies, including use ofenterprise management incentives options.
- Advice to P2P platform operators on tax issues, including withholding tax and VAT issues and securing rulings from HMRCs on points of uncertainty.
- Regularly advising on (S)EIS compliance matters and securing pre-investment rulings from HMRC
- Appearing live on BBC News 24 on the subject of European tax developments; published or quoted in The Sunday Times and numerous professional and business journals; contributing tax chapters in publications “Franchising” (UK and international issues) and“International Ex-Patriot Employment Handbook”.
Please note: The experience list above may include examples of work completed prior to joining Keystone Law.
By Chambers (2007) Tom Daltry offers “commercial and jargon free tax advice”.
Tom qualified as a solicitor in 1982. Prior to joining Keystone Law in 2009, he worked at Eversheds.