International tax advice 2017-12-28T15:53:54+00:00

International tax advice

The increasing focus on tax transparency, contribution and compliance has pushed the need for international tax advice up the global business agenda.

Tax authorities internationally are pursuing more stringent approaches to tax compliance and enforcement.

Cross-border taxation has never been a more topical, or divisive, issue.

Some governments are demonstrably keen to welcome and attract global corporate entities, to make use of their respective jurisdiction’s tax regimes and to do business in a conducive fiscal environment.

Other governments, and supranational organisations such as the EU, are proving less tolerant – militant even – toward current corporate cross-border tax practices. Here we are seeing a dogged pursuit to overhaul tax rules, remove the impact of base erosion and secure larger tax contributions from multinational companies active within their jurisdictions.

The spotlight on ‘Big Tech’s’ tax affairs, such as the likes of Amazon, Apple and Google, should be observed closely by the business community at large – and not just those with overtly global operations.

SMEs and OMBs that perhaps only ‘touch’ international aspects should watch developments in global taxation policy with interest, since any shift in tax assessment and contribution basis will, to a greater or lesser extent, impact business as a whole. A mooted corporation tax based on turnover or sales, for example, would have a devastating effect on many existing business models.

Implementation of the Base Erosion and Profit Shifting (BEPS) initiative is one such cross-border initiative that to date has proven far-reaching in its stated purpose of minimising variations and improving transparency in local tax regimes and reporting duties.

This creates an imperative for companies to take international tax advice for strategic and operational benefit.

Here to help

Enterprise Tax can help with all aspects of international tax advice. We work with companies to manage the tax implications of cross-border operations, advising on all aspects of international tax policy, rules and changes.

With cross-border tax concerns as far-ranging as company structuring, BEPS, transfer pricing, indirect taxation and outsourcing, international tax advice has the potential to create business risk as well as opportunities to drive competitive advantage through tax planning.

At ETC we have specific expertise in overseas property developments, working on large-scale international projects to create investment structures aimed at raising capital from UK resident investors and have also been involved in the establishment of a Real Estate Investment Trust (REIT) to be listed on the Channel Islands Stock Exchange.

Need international tax advice?

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“We have used the team at Enterprise Tax Centre on a number of occasions over the last few years, and have always found that the advice they give is practical and concise with a sound commercial basis. We would not hesitate to recommend them.”
Richard Saleh
Senior Partner, Salehs Solicitors
“The Enterprise Tax Consultants team are technically excellent and great people to work with. The team are diligent, thorough and hard working – highly recommended.”
Richard Gray
Barrister, Elysium Law
“We have used Enterprise Tax for a number of years now and as a result of their prompt, efficient and competitive service, they have become our only preferred partner when it comes to tax.”
Michael Clifford
Managing Director Europe, OCRA Worldwide

Key international tax issues for business

International tax is subject to constant change, presenting both risk and opportunity.

For businesses, international tax should be approached in the context of wider commercial and organisational objectives, and addressed during the formative stages of strategic initiatives. Some examples could include:

  • Cross-border direct and indirect tax issues
  • Cross-border company structuring, reorganisations or rationalisation
  • Tax aspects of cross border corporate sales and acquisitions
  • Implications of withholding taxes on cross-border payments
  • Cash repatriation
  • ‘Intangible’ property development, ownership and use
  • Tax issues created by employee secondments etc

Indirect taxation

A strategy will be required to manage indirect taxes across borders, impacting all consumption, transaction and transfer taxes areas such as VAT and GST (goods and services taxes).

Base Erosion Profit Shifting (BEPS)

BEPS, in the simplest of terms, is the Organisation for Economic Corporation and Development’s (OECD) 15-point action plan to ‘manage out’ tax planning strategies that take advantage of gaps and mismatches in tax rules across borders.

It is perceived that these strategies divert income, through artificial structures, to locations where the prevailing rate of corporate tax is low, but where the company carries out relatively little or no real activity.

The OECD is developing tools that countries can use to shape fair, effective and efficient tax rules that are coherent, have substance and transparent.

BEPS creates an imperative for businesses with multinational tax liabilities to stay up to date with progress on implementation of rule changes, particularly as more countries sign up to the initiative. This involves assessment of the various measures and adapting tax planning strategies accordingly.

What are the strategic challenges impacting international tax liabilities?

You may be a multinational company looking to review your global intangible property strategy, or to rationalise your corporate structure.

Whatever your strategic objective, we can support through cross-border planning and tax policy advice and strategies for optimising supply chain structures and related intercompany agreements in the face of a highly uncertain political environment, both at home and abroad. 

You may be a growing business looking to expand trade into new overseas markets, or to establish a physical presence in a new region.

This will give rise to new risks of ‘tax nexus’ as your company falls under a new set of tax laws that you must comply with.

Specialist international tax advice should help you to meet your requirements both in the new jurisdiction and at home on the most favourable terms for your business.

We can help with decisions such as whether a branch of the UK company, an overseas subsidiary of the UK company, introducing an intermediary company in another country with more advantageous treaty agreement, which can significantly reduce withholding taxes, or a separate stand-alone overseas company is the best alternative.

If you are planning to move or trade in a new jurisdiction, seeking early tax advice will ensure you are able to consider all relevant factors such as double taxation and benefit from favourable tax arrangements and the right structure for offshore arrangements can reduce tax exposure while still delivering the required level of control.

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