All cross border transactions have a tax implication. Whilst these can be relatively straightforward requiring little specialist consideration, once presence is established in a foreign jurisdiction matters become much more complex, often resulting in unforseen tax liabilities or missed opportunities for mitigation.
Tax mitigation through structuring
In countries subject to exchange control restrictions and very high personal and company tax rates, clients may wish to consider trading outside their host country. In a recent case concerning an overseas client, we established a UK company and organised the transfer of intellectual property rights to the new company in exchange for shares. We also tackled the task of helping to raise loan capital for the purpose of acquiring a participation in an overseas company and advised on the formation of an appropriate entity.
Maximum advantage was taken of the different tax rules between the client’s host country and the UK to ensure that all due benefits were exploited.
Such inter-jurisdictional tax matters call for expert international tax advice obtained in several countries. Through our RBI network, we were able to co-ordinate and provide the relevant expertise to ensure the effectiveness of the proposed structures. In addition, we were able to assist the client to co-ordinate and plan their future wealth retention in order to minimise direct taxation on personal income and capital.
If you’d like to know more about international tax planning, please email
geoffgoodyear@lubbockfine.co.uk
