Kyle O'Sullivan

Kyle O'Sullivan
  1. People /

Kyle O'Sullivan

Kyle O'Sullivan

Partner


London
Kyle O'Sullivan
  1. People /

Kyle O'Sullivan

Kyle O'Sullivan

Partner


London

Kyle O'Sullivan

Partner

London

T: +44 (0) 20 3400 4291

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Biography

Kyle is a Partner in the Tax Advice and Controversy team. He advises domestic and overseas clients on all aspects of UK corporate tax law, including public and private mergers and acquisitions, group reorganisations, joint ventures and private equity, corporate financing and disputes with HMRC.

Before joining BCLP, Kyle trained at Matheson in Dublin before working for eight years at Slaughter and May in London. He also has particular experience in the energy sector and has previously been on secondment at Vitol, one of the world’s leading energy and commodities companies, where he worked on tax planning, structuring acquisitions and other investments. 

Admissions

  • England and Wales

Related Practice Areas

  • Tax Advice & Controversy

  • Real Estate

  • Tax & Private Client

  • Tax Controversy

  • Taxation of Corporate Transactions

  • Taxation of Financial Transactions & Institutions

  • Real Estate Tax

  • Tax Credit Transactions

  • ESG & Energy Transition

Experience

  • Advised Sir Jim Ratcliffe, chairman of INEOS, on the acquisition of up to a 25% shareholding in Manchester United.
  • Advised Vodafone Group Plc on its entry into binding agreements with CK Hutchison Group Telecom Holdings Limited in relation to a combination of their UK telecommunication businesses, respectively Vodafone UK and Three UK.
  • Advised Arm Holdings plc on the UK aspects of its initial public offering on the Nasdaq Global Select Market.
  • Advised Allianz on its agreement with Sanlam, the largest non-banking financial services company in Africa, to combine their current and future operations across Africa (excluding South Africa).
  • Advised INEOS on the acquisition of BP’s global petrochemicals business, and on related financing arrangements.
  • Advised GoCo Group plc on its recommended combination with Future plc.
  • Advised Prudential plc on the demerger of its UK & Europe business (M&G Prudential) from Prudential plc, resulting in two separately-listed companies.
  • Advised Ocado Group plc on its online grocery retail 50/50 joint venture with Marks and Spencer Group plc.
  • Advised Allianz on its acquisition of Legal & General Insurance Limited, the general insurance business of Legal & General Group Plc.
  • Advised Takeaway.com on its recommended all-share combination with Just Eat plc.

Some of these representations were handled by Kyle prior to joining BCLP.

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Yesterday, the Government announced that the CGT rates for carried interest arising on or after 6 April 2025 will increase to 32%, in line with the 4% increase to the higher rate of CGT which took effect immediately.  That is just an interim measure however, and, from April 2026, a new regime will be introduced which will bring all carried interest within the scope of income tax. Importantly, the new regime will provide a lower effective tax rate of 32.625% for additional rate taxpayers (plus NICs) for certain “qualifying” carried interest. Details of the new regime were published by the Government, including a consultation, closing on 31 January 2025, requesting views on how to define what conditions should be introduced to access the lower effective tax rate. The shape of the new regime is not yet fully settled, and fund managers will need to monitor closely and, indeed, consider whether they want to respond to the consultation.  That said, it appears that, broadly speaking, the design of the new regime will more closely align the UK’s carried interest rules with regimes in some other European countries.
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