International tax planning - advanced

Expand your knowledge of international tax planning techniques for cross border activities

Accountants who are familiar with the international aspects of UK tax but wish to expand their knowledge of international tax planning techniques for cross border activities.

Illustrated with case studies, the course will be based on the real life experience of the Octave Ltd group, which expands from its UK base by gradual stages to become in international organisation with subsidiaries across the world. Numerous examples will illustrate the necessity of co-ordinating the UK and foreign aspects of cross border planning so as to achieve the best tax result in both jurisdictions As a result, constant reference will be made to specific tax features in major foreign jurisdictions in an international tax world that changes almost daily across the globe.

The speaker will be drawn from a pool of qualified professionals who specialise in this subject. Having worked for leading organisations they will bring their subject to life by relating the course content to real life case studies.

Unique tax features in selected countries.

The use of tax treaties.

The impact of EU law.

Entity classification and hybrids.

International anti-avoidance.

Cross border planning including:

• trading with, and in, the UK
• avoiding a taxable presence abroad
• foreign representative office
• foreign permanent establishments, partnerships and joint ventures
• incorporating, capitalising and licensing foreign subsidiaries, including favourable financing and licensing jurisdictions
• forex
• reorganisations, mergers and restructurings
• foreign acquisitions
• holding vehicles
• repatriating profits
• exit strategies.

The course will assume familiarity with the international aspects of UK corporate tax including corporate residence, controlled foreign companies, tax treaties, double tax relief and anti-arbitrage rules. These will be recapped briefly at the start of the course, and are covered in more detail in International tax planning - an introduction.