International Tax

With the increasing use of modern technology, more and more clients are extending their business interests across international borders. We assist clients in finding solutions and resolving tax issues that arise when assets are held in more than one jurisdiction.

Examples of what we advise on include:

Private client residence and domicile

  • Ensuring non-UK income remains outside the scope of UK tax;
  • Remittance basis claims;
  • An individual’s residence status;
  • How residence or domicile in a particular jurisdiction can be lost or established;
  • The taxation of non-resident landlords;
  • Emigration;
  • Claiming double tax relief for tax suffered overseas; and
  • Transfer of assets abroad.

Companies and corporate groups

  • Whether a branch or overseas subsidiary should be created to undertake international activities both at the outset of the venture and in the future;
  • Company residence and how residence in a particular jurisdiction can be lost or established;
  • The applicability and implications of the controlled foreign companies regime;
  • Transfer of assets abroad;
  • Transfer pricing issues;
  • Claiming double tax relief for tax suffered overseas and the overseas permanent establishment election;
  • The use of overseas trading losses and the ability to pool results from UK and overseas activities; and
  • VAT aspects of overseas trading.

Individuals and partnerships trading overseas

  • The use of taxable entities overseas, such as permanent establishments, and their exposure to foreign tax;
  • The use of overseas trading or capital losses and the ability to pool results from UK and overseas activities; and
  • VAT aspects of overseas trading.

Inward and outward investment

  • The appropriate structure to put in place to minimise the tax exposure in the UK and overseas at the outset and in the future.

Overseas employments

  • Breaking residence in the UK;
  • Undertaking duties in the UK through an overseas employment in a tax efficient manner; and
  • Reviewing dual-contracts and associated tax following HMRC challenge.

Offshore trusts and inheritance tax planning

  • Structuring non UK arrangements through offshore trusts and companies to deliver substantial UK income, capital gains and inheritance tax; and
  • Sheltering of capital gains offshore, particularly on UK situs assets.

Tax treaties and EU legislation

  • The use of double-tax treaties to minimise a company or individual’s liability to tax both in the UK and overseas; and
  • Maximising the benefits available under EU legislation for example in relation to the attribution of gains to non-resident companies and the transfer of assets abroad.

For more information on our International Tax services, please phone our TaxDesk on 0845 4900 509 or email taxdesk@gabelletax.com.

International Tax Specialist Group (ITSG)

Gabelle is part of ITSG, a network of tax specialists with members in over 30 countries around the world. Each ITSG member is highly experienced in international tax planning and is recognized as such by his or her peers. Members join the group “by invitation” after working successfully with other members.

 

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