Practical International Tax Planning for UK Businesses

A practical commentary on international tax planning for UK businesses operating abroad and for foreign businesses operating in the UK. It reads in a clear, logical and user-friendly manner. In view of its concise, transactional and business-oriented approach, this book will appeal to tax advisers and finance professionals at all levels of experience; as well as to students of international tax.

The international tax revolution sparked by:

• the OECD's Base Erosion and Profit Shifting ('BEPS') project
• the European Tax Avoidance Directive ('ATAD')
• other challenges such as EU State Aid investigations
• presents major challenges and calls for a practical analysis of how these developments will impact on
• international tax planning for UK businesses.

In addition, businesses and their advisers need to know on a timely basis how the rapid changes in UK and foreign taxes sparked by these and other global developments will impact them.

The first chapter rounds-up these international tax planning developments.

Each of the remaining chapters covers a specific step in the natural business cycle, as follows:

• UKCo exports goods and services abroad
• ForeignCo exports goods and services to the UK
• UKCo sets up a foreign branch
• ForeignCo sets up a UK branch
• UKCo incorporates its foreign branch into ForeignCo
• ForeignCo incorporates its UK branch into UKCo
• UKCo's foreign subsidiary
• ForeignCo's UK subsidiary
• UKCo: debt financing of foreign subsidiary
• ForeignCo: debt financing of UK subsidiary
• UKCo: equity financing of foreign subsidiary
• ForeignCo: equity financing of UK subsidiary
• UKCo incorporates a foreign holding company
• ForeignCo incorporates UK holding company
• UKCo licenses ForeignCo
• ForeignCo licenses UK subsidiary
• Finance and licensing companies
• ForeignCo repatraites profits to UKCo
• UKCo repatriates profits to ForeignCo
• UKCo acquires foreign business
• ForeignCo acquires UK business
• UKCo acquires and disposes of foreign real estate
• ForeignCo acquires and disposes of UK real estate
• Mergers and reqorgainsiations: UK outbound
• Mergers and reorganisations: UK inbound
• UKCo sells its foreign business
• ForeignCo sells its Uk business

​Each step in the cycle is analysed from both the UK and foreign tax viewpoint, with summaries, cross-references and citations to the relevant UK legislation, as well as references to relevant foreign tax rules in 20 of the jurisdictions that are among the UK’s main trading partners.