Business is now an exciting global arena, even for SMEs, with clients, suppliers and business centres across the world. This brings new challenges in bringing together different tax regimes to ensure that businesses are not taxed twice or pay a higher rate of tax. This can happen where the business is nonresident in the destination country or structured in a particular way. Our tax team specialise in cross border transactions and advising on how to structure your arrangements. These might include:


  • Whether to set up a subsidiary or branch (permanent establishment). There are different regulatory requirements and tax treatments of each.
  • Which entity to choose such as a company or LLP and how this should be owned. An LLP or limited liability partnership is transparent for tax purposes in the UK meaning each partner is taxed directly in their own right.
  • Holding companies for groups of companies to facilitate group relief , keep different aspects of a business separate and enable partial sales.
  • Repatriation of profits which can take several forms and must be considered in the light of individual circumstances.
  • Double tax relief including claims to prevent double taxation where available and maximising credit for foreign tax paid.
  • Withholding taxes on income paid or received from a jurisdiction and reducing the rates payable, in some cases to nil.
  • Exemption from tax for dividends
  • Exemption from tax on the sale of group companies
  • Internationally mobile employees bring queries about the employer’s obligations; where salaries should be taxed, and whether national insurance is payable.
  • VAT and duties arising on cross border transactions.


We are happy to have a no obligation call or meeting to see how we might help you.