International Tax
Whether you are a UK or overseas headquartered multinational, our leading international tax professionals throughout the UK can help you with every aspect of international tax planning and compliance.
We can provide advice on a broad range of aspects including initial overseas investment, management of your global effective tax rate, financing your international operations and cross border transactions and structuring. We use our specialist knowledge to understand your business and deliver tailored tax solutions that are aligned with your wider business strategy.
Issues and trends
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Our solutions
We can offer a full range of international corporate tax services across all industry sectors for both UK and overseas headquartered multinationals. We work closely with our specialist colleagues in areas such as transfer pricing and with international tax specialists across the international network of Deloitte member firms to deliver a seamless service and bespoke solutions for your business.
Examples of the services we can provide include:
General:
- Tax compliance – Our core client teams can provide both tax advisory and tax compliance services ensuring we develop a deep understanding of your business, which leads to an efficient tax compliance process and the provision of appropriate and timely advice. We can also work closely with our tax accounting and tax management consulting colleagues to provide tax technology and process improvement solutions.
- Transaction services – We can provide tax due diligence and structuring advice on acquisitions, disposals, mergers and other corporate restructuring projects. On large transactions we work with our specialist mergers and acquisitions tax group.
- Worldwide Debt Cap – We can help clients understand the impact of the new worldwide debt cap rules on their group's UK tax position, both from a forecasting and compliance perspective. We have two spreadsheet tools which can be used to help groups calculate the forecasted impact of both the gateway test within the rules (most likely to apply to groups headquartered outside of the UK) and the actual detailed calculations. We also advise groups on how they may want to consider improving their debt cap position.
UK headquartered multinationals
- Structuring of overseas investments – together with international tax specialists across the international network of Deloitte member firms we can advise on the UK and non-UK tax considerations for UK headquartered multinationals investing overseas, whether this is as an organic expansion or the acquisition of new operations. Relevant considerations include deciding on an appropriate entity structure (e.g. branch or local company) and the taxation of profits and losses in the local jurisdiction and in the UK parent. We also have deep knowledge and practical experience in the field of the UK’s wide-ranging controlled foreign company rules that must be borne in mind on an ongoing basis.
- Financing of overseas operations – we have in-depth knowledge of the tax and commercial considerations involved in the provision of finance to overseas operations and specifically the structuring of finance in tax effective ways. Typically this will involve analysing the respective treatment of debt, equity or hybrid investments in terms of local tax deductibility, withholding taxes and the UK tax consequences as funds are repatriated to the UK.
- Relationship with tax authorities – with our deep technical knowledge and experience we are able to assist in obtaining clearances from HMRC and overseas tax authorities, and defending against tax authority audits on all aspects of a multinational’s international tax affairs.
Overseas headquartered multinationals:
- Initial investment into the UK – We can advise on all tax issues associated with investing into the UK, including permanent establishment issues, setting up branches or subsidiaries and registering with HMRC for corporation tax, VAT and employment taxes.
- Financing UK activities – We can advise on tax effective financing structures, withholding tax mitigation and potential restrictions on the deductibility of interest including thin capitalisation, worldwide debt cap, unallowable purpose and arbitrage.
- UK as a holding company location – We can assist you with considering or setting up a UK holding company, including providing a comparison between the UK and other holding company locations.
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