We help UK groups and founders with international tax planning that works in real life. Our method combines cross-border tax strategies with easy-to-follow steps. These steps are based on OECD guidance and standards from the G20, the EU, and Asia-Pacific.
We create tax structures that help businesses grow. This includes models in Canada, Barbados, and Singapore. We also separate different types of income and manage rules like Subpart F and PFIC.
Our services include OECD-compliant transfer pricing and audit defence. We handle cross-border reorganisations and M&A. We also manage international debt and financing.
We aim to reduce withholding tax and meet filing duties. This includes NR4 and T106 forms. We also align treasury and capital structures with risk management.
We make sure supply chains follow BEPS outcomes and EU rules. We also ensure compliance with US GILTI and Country-by-Country Reporting. Our goal is to simplify complex laws and keep businesses compliant and in control.
Understanding International Tax Planning
We assist groups and founders in managing their cross-border activities. This ensures profits are distributed smoothly, cash returns quickly, and tax filings are on time. Our approach respects local laws, OECD BEPS guidelines, and international treaties. It also caters to the practical needs of finance teams in the UK and worldwide.
Definition and Importance
International tax planning involves designing financial flows to achieve efficient outcomes legally. It aligns with a company’s goals, using transparent records that can withstand scrutiny.
We focus on following BEPS actions closely. This includes transfer pricing and country-by-country reporting. It helps avoid permanent establishment claims and secures treaty relief when possible. It also aids in reducing withholding taxes on dividends, interest, and royalties.
For businesses in the G20, EU, and Asia-Pacific, good planning is crucial. It stabilises treasury needs and protects against market volatility. It keeps the effective tax rate stable, aligning with the board’s global tax goals.
Key Objectives of International Tax Planning
- Reduce global tax exposure through robust HoldCos, participation exemptions, and treaty routing backed by substance and the principal purpose test.
- Ensure legal compliance by aligning models with BEPS outcomes, local anti-avoidance rules, and capital gains and WHT regimes.
- Manage risk with PE analysis, hybrid mismatch controls, and thin capitalisation limits built into funding.
- Optimise cash and IP locations so treaty relief applies and withholding tax reduction is obtained lawfully.
- Avoid double taxation via DTAs and the MLI, keeping global tax objectives clear and measurable across markets.
Benefits of International Tax Planning
We make sure profits are taxed only once, in the right place. We use places like Ireland, the Netherlands, and Singapore to do this. This way, we meet business needs and keep tax rates low while ensuring good governance.
Tax Minimisation
We plan supply chains and finances to fit our business needs. We use Ireland’s 12.5% rate for trading and the Netherlands for holding companies. Luxembourg is good for financing, Hungary for operations, and Singapore for treasury and IP.
We also plan for dividends, interest, and royalties to save on taxes. This helps avoid extra taxes and keeps our business strong.
Legal Compliance
We focus on following the law from the start. We make sure our transfer pricing files meet OECD standards. For US and Canadian groups, we handle all the necessary paperwork.
We also work on Advance Pricing Agreements to avoid audits. This keeps our tax plans safe and in line with the law.
Risk Management
We check our business footprint to avoid risks. We make sure our capital is right and our structures are safe from thin capitalisation. We also watch out for hybrid mismatches and profit diversion.
We use tools to manage risks like foreign exchange and interest rates. This keeps our tax stable and in line with the law, helping us save on taxes.
Common Strategies in International Tax Planning
We create effective plans for businesses across borders. Our goal is to help UK companies with clear documents, strong governance, and treaty benefits. We also keep up with changing rules on disclosure and substance.
Transfer Pricing
We use OECD transfer pricing rules that fit real business needs. This includes pricing for services, royalties, and distribution margins. It also covers the cost of intangibles used in different markets.
Our approach follows the master file local file standard. It links to country-by-country reporting for consistency. This helps defend against audits from HMRC to the Bundeszentralamt für Steuern and aligns with G20 rules.
For certainty, we aim for an APA with HMRC or a bilateral agreement. This can stabilise margins, reduce disputes, and align with BEPS on risk, people functions, and asset ownership.
- Map value chains to confirm where people manage risks and intangibles.
- Test benchmarks for routine and entrepreneurial returns.
- Prepare controls that evidence policy in monthly finance cycles.
Tax Treaties and Agreements
We use double tax treaties to manage cross-border flows of dividends, interest, and royalties. With the right structure, groups can reduce withholding tax using UK–Canada or UK–France treaties, or EU rules for historic holdings.
For example, the France–Canada treaty on dividends is similar to Article 10. The Canada–US framework is often used for ULCs, LLCs, or C corporations. The Netherlands is popular in the EU, especially with the Parent-Subsidiary Directive, subject to substance tests.
Treaty access now depends on the MLI principal purpose test and other anti-avoidance tools. We check purpose, substance, and routes to ensure claims are genuine and supported by documentation.
- Check residence, beneficial ownership, and limitation-on-benefits terms.
- Align legal forms, such as LLPs, with treaty characterisation.
- Maintain evidence for claims, renewals, and competent authority processes.
The Role of Legal Structures
Legal structures shape how profits are made and risks are managed. They ensure governance is transparent. We match business needs with tax and regulatory rules. This way, every entity has a clear purpose and meets economic substance standards.
Offshore Companies
We set up holding companies in places like Singapore, Luxembourg, and Cyprus. These locations offer treaty access and efficient repatriation. They also meet substance requirements under BEPS and local rules.
In Luxembourg, a Soparfi can consolidate investments while avoiding anti-avoidance rules. Cyprus offers 0% dividend withholding tax under certain conditions. Singapore requires board control, skilled staff, and premises for economic substance.
In Canada, we look at unlimited liability companies and other flow-through entities. This matches income character and credit use. Across all jurisdictions, we ensure transfer pricing, management, and DAC reporting align with reality.
- Purpose-built entity charts that withstand review
- Board procedures, minutes, and local decision-making
- Cash, IP, and funding flows mapped to economic substance
Trusts and Foundations
We use trusts for international planning, covering succession, asset protection, and cross-border holdings. These structures work with tax treaties and local laws. They also meet CRS and DAC reporting standards.
For families tied to Canada, New Zealand, or the EU, we manage trusteeship and protectors. Foundations are used in civil law countries to mirror family governance. They ensure board roles, accounts, and distributions follow the deed and economic substance standards.
- Transparent reporting under CRS and DAC frameworks
- Defined roles for trustees and foundation councils
- Integration with operating companies and holding companies for coherent oversight
Double Taxation Agreements (DTAs)
DTAs clarify who taxes income when two countries are involved. They help manage residence and source taxation to avoid double taxation. They also outline how to resolve disputes through MAP and how the MLI affects treaty benefits.
What are DTAs?
DTAs are treaties that decide who taxes business profits, dividends, interest, and royalties. They define when a permanent establishment exists and use tie-breaker rules for those in two places. The goal is to ensure double tax relief and keep taxes where they belong.
Real cases show the impact. A dividend from France might face lower withholding tax rates with treaty benefits. In Germany, BZSt can exempt at source. The place of management and control tests often decide where profits are taxed first.
How DTAs Work
Each article in a treaty guides the result. Article 7 covers business profits, Article 10 covers dividends, and Article 12 covers royalties. Relief comes through exemption or foreign tax credit, matching treaty limits on withholding tax rates.
The MLI updates many treaties with anti-avoidance tools, including a principal purpose test for treaty benefits. If disagreements arise, MAP offers a way for tax authorities to resolve issues. Disclosures and filings, like T106 and T1134, support positions and align residence and source taxation with the treaty framework.
The Impact of Brexit on International Tax Planning
We look at Brexit’s tax impact with a practical eye. UK–EU tax planning needs a closer look at withholding rules and real substance. We compare the treaty network post-Brexit to cash flow goals and risk levels.
Changes in Tax Treaties
Most UK bilateral treaties still apply. But, the loss of the parent-subsidiary directive means EU directives no longer protect UK–EU dividends and interest by default. Now, relief depends on domestic law and each treaty’s terms, leading to varying rates.
We compare routes through Ireland, the Netherlands, Luxembourg, and Cyprus. We test substance to meet principal purpose tests. Moving holding companies to an EU hub has reduced gross dividend leakage in some cases, thanks to local rules setting 0% withholding.
- Confirm treaty eligibility and limitation-on-benefits before distributions.
- Re‑paper intercompany funding to align with arm’s‑length pricing and MLI standards.
- Model UK–EU tax planning outcomes for dividends, royalties, and interest under domestic WHT.
New Opportunities
Brexit offers a chance to reset holding chains, IP hubs, and supply paths. Treaty-based planning with a UK LLP can achieve non-resident treatment in certain cases. EU-aligned structures in Ireland, the Netherlands, Luxembourg, and Cyprus provide alternative market access and rulings.
We see value in treasury and operating model work. It includes optimising capital stacks, hedging currency swings, and refining permanent establishment footprints for UK businesses trading into the EU and beyond. This may involve selective relocation of holding companies, tested against the treaty network post-Brexit and local substance rules.
- Align cash pooling and hedge policies with forecasted UK–EU flows.
- Locate IP where development, enhancement, maintenance, protection, and exploitation occur.
- Stage gateways to manage the Brexit tax impact without over‑engineering structures.
Compliance with International Regulations
We make sure tax operations follow global rules. This keeps cross-border reporting clear, on time, and defendable. Our method combines BEPS, ATAD, and more to lower audit risk and keep things simple.
OECD Guidelines
We follow OECD Transfer Pricing Guidelines closely. We use master and local files to show how prices are set and value is created. Advance Pricing Agreements with HMRC or other authorities can add certainty in tight margins or complex models.
At the heart of BEPS compliance is substance. We check functions, assets, and risks. We also look at permanent establishment exposure, especially with digital presence. For EU rules, we map ATAD impacts and refresh CFC reporting, linking it to CBCR for consistency.
Our teams tackle the EU MDR by spotting hallmarks early. We prepare clear disclosures and align them with local rules. This helps keep audit trails clean and documentation strong across borders.
FATCA and Common Reporting Standards
We set up entity status and onboarding for FATCA and CRS. We ensure accurate classification and check beneficial ownership. We review accounts and controlling persons to match source records and cut down on follow-up queries.
For trusts, including those in New Zealand, we handle CRS disclosure. We organise trustee data and settlor and beneficiary records. We work with banks like HSBC and Barclays to align file formats while protecting privacy in the UK and abroad.
We track GILTI exposure for US persons and reconcile CBCR with local returns. We maintain transfer pricing documentation to support filings. This framework ties MDR to FATCA, CRS, and CFC reporting, offering a single view of compliance.
- Core controls: BEPS compliance, ATAD testing, and CBCR-coherent narratives.
- Reporting cadence: FATCA, CRS, MDR, and CFC reporting aligned to statutory dates.
- Risk checks: GILTI reviews, PE analysis, and refreshed transfer pricing documentation.
The Importance of Professional Advice
Planning across borders is always changing. Rules change, treaties evolve, and audits can come at any time. We offer experienced international tax advisors to keep your structure up to date and practical for everyday use.
Choosing the Right Advisors
We connect you with a global tax desk that spans London, New York, Toronto, Dublin, Singapore, and Frankfurt. This network helps coordinate rules across borders, creating a clear plan for you.
Our team combines legal and tax expertise. They handle APAs, treaty claims, and talks with HMRC, the Canada Revenue Agency, the IRS, and EU authorities. You get a single point of contact with specialists who understand the local scene.
- Joined‑up advice across jurisdictions, not siloed opinions
- Real‑time updates on OECD and EU positions that affect pricing and reliefs
- Practical execution so filings, elections, and rulings stay aligned
Regular Reviews and Updates
We keep your structures in line with BEPS guidance, the MLI, ATAD, DPT, thin capitalisation limits, and post‑Brexit changes. We plan annual reviews, mid‑year checks for reorganisations, and quick help for expansions or audits.
Through our global tax desk, we update treaty positions, watch for permanent establishment risks, and adjust financing, IP, and supply chains. This ensures every move is compliant and tax-efficient, with legal and tax counsel ready for rule changes.
Identifying Tax Residency
We first check where you are taxed, as this affects your rates, reliefs, and filing duties. We use both domestic laws and treaty outcomes. This helps avoid unexpected taxes and manage your tax status across borders.
Factors Determining Residency
For individuals, we look at tax residency tests like the UK Statutory Residence Test. We also consider day counts, ties to the UK, and your home and family life. When you’re taxed in two places, we use treaty rules to decide where you’re really taxed.
For companies, we check where they are set up and where they are managed. The place of effective management is key. We look at board decisions and real substance to see if a company is really managed there. This helps avoid tax risks and aligns with international tax rules.
- Board minutes, decision logs, and travel data help show who makes decisions.
- Having real substance in the host country helps prove effective management.
- Treaty access depends on meeting certain tests under the MLI.
Implications of Residency
Being resident in a country affects your access to double taxation agreements. It also impacts withholding taxes and relief claims. It can lead to extra reporting, like T106 and T1134, if you’re in certain situations.
When you’re taxed in two places, treaty rules can affect your tax rates and audits. In Canada–Australia and Canada–United States cases, aligning management with treaty goals can reduce tax risks. This keeps treaty benefits while avoiding double taxation.
- Knowing your residency status helps avoid losing foreign tax credits and manage cash tax timing.
- Strong evidence supports treaty claims and defends your tax status during audits.
- Regular checks keep your residency status up to date as things change.
Planning for Expatriates
We assist mobile staff and their employers in staying compliant across borders. Our strategy combines expatriate tax planning with practical payroll control. We also do treaty analysis and risk reviews for modern remote work.
Tax Obligations for UK Nationals Abroad
UK nationals working abroad need clear tax rules. We help them understand where they pay tax and when to file. We check if they’re taxed in more than one place for things like bonuses or share awards.
We plan for expatriate tax, including risks from remote work. We look at days, duties, and authority to make sure they follow OECD rules and local advice.
We also look at social security totalisation agreements. This helps avoid double charges and ensures the right paperwork. We guide on reporting for offshore accounts under CRS and FATCA if needed.
Considerations for Foreign Workers in the UK
Foreign workers in the UK need accurate payroll from the start. We set up PAYE, look at split payroll options, and prepare treaty relief claims. This ensures income is taxed correctly.
We check if remote work creates a permanent establishment in the UK. If it does, we help change how things are done to avoid this.
Our support includes checking social security totalisation, tracking short-term business visitors, and reviewing benefits-in-kind. This leads to clean records, timely submissions, and fewer surprises for everyone involved.
Wealth Management and International Tax
We make sure wealth goals match tax rules across borders. This keeps portfolios efficient and easy to move. Our planning mixes structure, control, and clear reports. It helps families grow their wealth while managing risks and planning for the future.
Investment Strategies
We create investment plans that use listed securities, private equity, and real estate worldwide. We choose holding companies in top EU spots. These companies must have substance, control, and follow Anti-Tax Avoidance Directive rules.
For property, we plan how to rent it out and sell it. We use treaty relief and local filing rules. Trusts hold assets for the long term while keeping reports clear under UK and global rules.
Our treasury work includes managing cash, hedging currency risks, and smart repatriation. We set up funds and derivatives to manage risks and taxes. We keep estate tax and succession planning in mind from the start.
Inheritance Tax Considerations
We look at family assets and plans to guide trusts and cross-border setups. We aim to protect heirs while following local laws and disclosure rules.
For families with ties to the US or Canada, we align UK rules with their estate and gift laws. We use treaty rules if they apply. We review real estate, business interests, and portfolios for estate tax planning. This ensures smooth wealth transfer and governance.
We support succession planning with clear wishes, solid structures, and documented decisions. We test plans with scenarios. This checks how taxes, exemptions, and timing work across borders.
Technology’s Role in International Tax Planning
We use tax technology to make sense of complex rules across borders. It reduces manual work, improves control, and gives us accurate data for quick decisions.
Digital Solutions for Compliance
Our system combines e-filing with checks to ensure everything matches. It uses tools from SAP, Oracle, and Workiva to manage records and track taxes. This helps us meet the OECD’s rules.
- CBCR systems create reports and schedule MDR submissions with audit trails.
- TP documentation tools put together master and local files, matching data with contracts and invoices.
- Engines calculate CFC and GILTI exposures, and keep treaty claims consistent.
These tools make approvals faster and reduce time, but still let teams keep an eye on things.
Data Analytics for Effective Planning
We use data analytics to predict outcomes and test plans. Cloud dashboards help us understand cash, rates, and risks. This guides our decisions on capital and supply chains.
- FX and interest simulations help with treasury and capital structure, with alerts for hedge gaps.
- Workforce analysis flags risks of permanent establishment as teams move across borders.
- Signal tracking shows when to bring cash back and when to simplify our structure.
Analytics also helps with managing documents for APAs and exemptions. It links planning to controls and keeps our e-filing on schedule.
Sector-Specific Tax Considerations
Different industries face unique tax challenges when crossing borders. We create plans that meet business goals and follow the law. Our strategy combines smart structuring with clear reporting in key markets.
Real Estate Investments
We understand the tax issues in property across buying, owning, and selling. We use SPV structures to manage risks and cash flows. We also plan for withholding taxes and finance terms.
In Spain, we use Sociedad Limitada entities for SPV routes. We also handle Canadian ownership and controlled foreign affiliate reporting. When selling, we check if Section 116 filings are needed and manage timelines to protect funds.
For EU-wide portfolios, we look at Portugal and Cyprus for holding options. We balance exemptions, interest limits, and hybrid rules. We also test corporate layers to delay tax without breaking substance rules. We keep UK reporting in line with local calendars.
Financial Services and Taxation
Financial groups often use treasury centres and IP hubs. We design models for Singapore Section 13 and Hong Kong’s two-tier profits tax. The first profits tranche is taxed at 8.25%, subject to substance and transfer pricing.
We help global treasury teams with funding, capital resets, and hedge design. We also handle trading flows and anticipate tax authority scrutiny. Our files cover intra-group financing, thin capitalisation, and hybrid mismatch rules under ATAD2 and Australia’s framework.
We focus on cross-border reporting from the start. We build audit-ready packs for MDR disclosures and align withholding tax planning with instrument terms. This approach creates a controlled footprint that meets regulatory needs without slowing down transactions.
Future Trends in International Tax Planning
International tax rules are changing fast. Governments are moving towards BEPS 2.0 and a global minimum tax. The OECD and European Commission are making anti-avoidance tests stricter.
Businesses with operations across borders will face more scrutiny. This includes transfer pricing, financing, and substance.
Changes in Global Tax Policies
Policy changes are gaining speed. The EU’s ATAD has led to stronger CFC regimes. Rules for CFC and GILTI are evolving, affecting profit taxation in the US and abroad.
A global minimum tax is becoming more common. Countries are implementing Pillar Two.
Tax treaties are getting tighter. This is thanks to MLI updates and principal purpose tests. Thin capitalisation and interest limitation rules are also getting stronger.
Reporting is becoming more detailed. This includes Country-by-Country Reporting and Mandatory Disclosure Rules. It’s all about being transparent and audit-ready.
Hubs like Singapore and Ireland are updating their rules to match BEPS 2.0. Companies are reviewing their models to stay compliant with stricter standards.
The Shift Towards Digital Economy Taxation
Digital businesses are under more scrutiny. Many places are introducing digital services taxation. OECD talks are ongoing.
Transfer pricing for digital services is changing. This includes intangibles, platform fees, and user-based value. Documentation and Advance Pricing Agreements are key for certainty.
Rules for remote service providers are being refined. This is based on OECD guidance and local rules. Asia and Europe are setting examples.
Looking ahead, digital rules, BEPS 2.0, and the global minimum tax will shape group structures. MLI updates and evolving CFC and GILTI rules require agile governance and data-driven monitoring.
Case Studies in Effective Tax Planning
Real results show us what works. These treaty relief case studies cover Europe, North America, and Asia. They show how structure, substance, and timing affect outcomes. We use PE mitigation, IP migration, EU holding structures, cash repatriation, and transfer pricing audits to keep benefits.
Success Stories from Various Industries
- France–Canada dividends at 0% by pairing the treaty with the EU Parent-Subsidiary Directive, after verifying substance and prior transfer pricing audits.
- A Dutch holding company secured 0% inbound dividends from the EU, with PE mitigation and clear board control to support cash repatriation.
- Luxembourg Soparfi aligned with ATAD rules to protect interest deductions and facilitate IP migration with arm’s length royalties.
- Poland manufacturing used compliant transfer pricing audits and Article 7 sourcing to ring‑fence profits and enable steady cash repatriation.
- Cyprus served as a post‑Brexit conduit for dividend flows while safeguarding EU holding structures and treaty access.
- Spain Sociedad Limitada for real estate met IRNR obligations and enabled PE mitigation through local asset management protocols.
- Singapore treasury and IP hub under Section 13 delivered reduced rates on royalties and dividends, easing IP migration.
- Hong Kong royalty routing achieved the 8.25% tier with clear functions and risks, supporting quick cash repatriation.
- Japan shifted to a limited‑risk distributor to lower PE exposure, pairing the model with documented comparables.
- Australia addressed PE and residency risks using OECD commentary, preserving treaty relief and dividend flows.
- Germany obtained BZSt exemption certificates to cut withholding, improving timeline certainty for cash repatriation.
- United States structure employed a C‑Corp with LLC blockers to navigate Subpart F and PFIC while retaining treaty benefits.
- Hungary delivered an IP migration to the 9% rate with treaty‑protected royalties and safeguarded EU holding structures.
Lessons Learned
- Substance and tight documentation decide treaty access and withstand transfer pricing audits; they also support PE mitigation.
- Aligning operating models with BEPS guidance reduces disputes and stabilises cash repatriation across borders.
- Early APAs and exemption certificates, such as BZSt, trim withholding and keep EU holding structures efficient.
- Clear tests for active versus passive income prevent FAPI and Subpart F leakage and protect IP migration outcomes.
- Annual reviews adapt to MLI, ATAD2, and Brexit shifts, preserving treaty relief case studies as living frameworks.
How We Can Assist You
We offer full support to businesses in the UK dealing with international tax rules. Our team combines strategic advice with practical help. We make sure every step is clear, on time, and can stand up to scrutiny.
Our Services Overview
We help with setting up the right company structure and planning for big changes like mergers. We also guide on how to follow OECD rules for fair pricing. Our services include making master and local files, planning for tax on international deals, and checking if you have a permanent establishment.
We handle taxes for executives and global teams, set up for international property, and take care of all tax filings. This includes things like CBCR, CFC/GILTI/FAPI, MDR, and FATCA/CRS. We also manage returns like T106, T1134, 5471, 8865, and 8938, making it easy for you.
Our team is skilled in making the most of your finances, including hedging and cash pooling. We make sure your money plans match your business goals in different markets.
Tailoring Strategies to Your Needs
We begin with a meeting to understand your global situation and goals. Then, we do a detailed check of your tax situation in different places. This helps us spot any risks or benefits early on.
We then create a plan using companies, trusts, and holding structures. This balances what you need to do with what you have to follow. We make sure everything is set up right, working with UK and foreign lawyers to keep things on track.
We keep in touch with you regularly, updating your tax plans and filings as needed. Our global network, including strong ties in the UK, Europe, and Canada, helps us simplify things. This way, we ensure you get the best results in international tax, structuring, treasury, APA support, and global mobility tax.
Contact Us for More Information
Speak to tax advisor teams who know the UK and global tax rules well. Our international tax consultation UK service helps make complex issues clear. We start with a detailed cross-border assessment and a compliance health check.
Then, we outline practical steps you can take with confidence.
Consultation Process
We start with a private review of your international operations and goals. We look at legal entities, financing, and more. Our work includes treaty review, residency testing, and mapping filing obligations.
We also check risks under the MLI, ATAD, and BEPS, along with local rules.
After that, we show you clear options with tax, compliance, and operational impacts. You get a summary in plain English and a focused compliance health check. This helps you stay ready for audits and improves control over cash and reporting.
Getting Started with Your Tax Planning
Prepare organisation charts, intercompany agreements, and transfer pricing files. Also, have financing details and prior filings ready. We work with foreign counsel and seek APAs or exemption certificates when needed.
Our team handles the cross-border assessment so you can focus on your business. We offer ongoing support with annual reviews, treaty updates, and monitoring of EU and US tax changes. We help with audits and aim to make international tax clear and efficient for UK businesses and international clients.
