Linda Warner

Linda, head of the tax team, advises on all aspects of UK taxation and the interaction with international tax regimes.

Before joining Roffe Swayne, Linda was a partner at Smith & Williamson specialising in owner-managed businesses and their owners. Linda continues to work with Surrey owner-managed businesses, particularly within the property and technology sectors, and provides effective tax strategies to reduce and manage their tax liabilities

Linda also provides tax advice for high-net-worth individuals including non-domiciled individuals on income tax mitigation strategies, property taxes, capital gains tax and inheritance tax.

Linda advises on a wide range of areas but specialises in:

  • M&A advice on corporate restructuring, due diligence and warranty protection.
  • exit strategy planning
  • SEIS, EIS and VCT relief
  • Share option schemes including EMI and other forms of employee ownership including employee ownership trusts
  • Capital taxes planning for high-net worth individuals

Member of the UK200Group Tax Panel of experts. Linda often acts as an expert witness for divorce proceedings and other matters.

Work highlights
  • Advising on a number of group reconstructions, including a reconstruction involving two active companies, transferring five principle trades to new stand-alone companies where stamp duty mitigation was also important.
  • Facilitating the sale of a successful business to an Employee Ownership Trust.
  • Advising on the structure for and implementing proposals for several company purchase of own shares and obtaining clearance from the Revenue thereon.
  • Advice on share option arrangements and implementation of EMI schemes. Advice in relation to Employee Shareholder Shares.
  • Advising on structuring employment income for a number of internationally mobile individuals including consideration of the disguised remuneration rule and pension planning.
  • Advising clients on IHT mitigation opportunities including BPR relief and other share structuring, regular giving, the use of trusts and advice on the structure of wills. Advice and implementation of a family investment company to facilitate the phased transfer of complex asset and business interests in a tax efficient manner whilst ensuring commercial protection was maintained.
  • Advising non-domiciled and non-resident clients on tax structuring, UK statutory residence tests and remittance issues including the interaction with double tax treaties. Advising UK resident clients on the tax issues surrounding offshore trusts and other arrangements.
  • Advising on complex principal private residence relief cases and the High Value Residential Property rules. Structuring advice for property investment holdings.
  • Dealing with several technical tax enquiries including negotiating penalty settlements.

Outside of work Linda enjoys badminton, walking and any opportunities for singing

Linda Warner

LinkedIn profile

Contact Linda