Practical International Tax Planning
- What’s new in international tax planning
- About the authors
- 1. Anti-avoidance including BEPS, ATAD, state aid, transfer pricing and double tax treaties
- 2. UKCo exports goods and services abroad
- 3. ForeignCo exports goods and services to the UK
- 4. UKCo sets up a foreign branch
- 5. ForeignCo sets up a UK branch
- 6. UKCo incorporates its foreign branch into ForeignCo
- 7. ForeignCo incorporates its UK branch into UKCo
- 8. UKCo’s foreign subsidiary (ForeignCo)
- 9. ForeignCo’s UK subsidiary (UKCo)
- 10. UKCo: debt financing of ForeignCo
- 11. ForeignCo: debt financing of UKCo
- 12. UKCo: equity financing of ForeignCo
- 13. ForeignCo: equity financing of UKCo
- 14. UKCo incorporates a foreign holding company
- 15. ForeignCo incorporates UK holding company
- 16. UKCo licenses ForeignCo
- 17. ForeignCo licenses UKCo
- 18. Finance and licensing companies
- 19. ForeignCo repatriates profits to UKCo
- 20. UKCo repatriates profits to ForeignCo
- 21. UKCo acquires a foreign business
- 22. ForeignCo acquires UK business
- 23. UKCo acquires and disposes of foreign real estate
- 24. ForeignCo acquires and disposes of UK real estate
- 25. Mergers and reorganisations: UK outbound
- 26. Mergers and reorganisations: UK inbound
- 27. UKCo sells its foreign business
- 28. ForeignCo sells its UK business
- Appendix 1: Controlled foreign companies summary
- Appendix 2: Corporate interest restriction summary
- Appendix 3: Diverted profits tax summary
- Appendix 4: Foreign branch exemption summary
- Appendix 5: Hybrid mismatch legislation summary
- Appendix 6: Gains of closely held foreign companies (TCGA 1992, s. 3–3C) summary
- Appendix 7: UK VAT on cross-border supplies of goods and services summary
Welcome to Practical International Tax Planning, for UK Businesses Croner-i's practical commentary on international tax transactions.
This service is a concise, comprehensive and practical guide to international tax planning for UK companies doing business abroad and for foreign companies doing business in the UK. Its objective is to keep the topic as uncluttered as possible so as to bring the essential tax planning considerations to the fore. It therefore dispenses with a detailed analysis of the relevant UK and foreign tax legislation underlying the tax planning, which it instead deals with in links, summaries, tables and appendices for convenient reference.
Because of the service’s transactional and practical approach, the tax practitioner, finance professional and student will be able to focus on the specific cross-border transaction requiring his or her attention, instead of having to sift this out from detailed comment on the relevant legislation, and then having to identify which areas of UK and foreign legislation and practice are applicable to the transaction under review. This means that a certain amount of repetition is inevitable in order to make each section self-contained to the specific transaction under focus. In other words, this is a practical hands-on guide for everyday work in the office and a roadmap for the student of international tax.
In order to highlight the essence of the subject and to underline the basic principles, most of the discussion centres around two companies doing cross-border business with each other, namely ‘UKCo’ and ‘ForeignCo’. Of course, real life is not like that and in practice a lot more companies are likely to be involved, often in multiple jurisdictions. Examples of these multinational situations are included in case studies and diagrams throughout the text.
Commentary on foreign jurisdictions concentrates on the following 20 countries, being amongst the most significant destinations for UK outbound and inbound investment and some of the UK’s top trading partners. The text refers to them as ‘the Selected Jurisdictions’:
Australia, Belgium, Brazil, Canada, China, France, Germany, Hong Kong, India, Ireland, Italy, Japan, Luxembourg, the Netherlands, Poland, Singapore, Spain, Sweden, Switzerland and the US.
Other foreign jurisdictions are mentioned where appropriate.
The service was written by Allan Cinnamon. Updates are jointly written by Allan Cinnamon and Zigurds Kronbergs.
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