A practical commentary on international tax planning for UK businesses operating abroad and for foreign businesses operating in the UK. It reads in a clear, logical and user-friendly manner. In view of its concise, transactional and business-oriented approach, this book will appeal to tax advisers and finance professionals at all levels of experience; as well as to students of international tax.
The international tax revolution sparked by:
- the OECD's Base Erosion and Profit Shifting ('BEPS') project
- the European Tax Avoidance Directive ('ATAD')
- other challenges such as EU State Aid investigations
presents major challenges and calls for a practical analysis of how these developments will impact on international tax planning for UK businesses. In addition, businesses and their advisers need to know on a timely basis how the rapid changes in UK and foreign taxes sparked by these and other global developments will impact them.
The first chapter rounds-up these international tax planning developments.
Each of the remaining chapters covers a specific step in the natural business cycle, as follows:
- UKCo exports goods and services abroad
- ForeignCo exports goods and services to the UK
- UKCo sets up a foreign branch
- ForeignCo sets up a UK branch
- UKCo incorporates its foreign branch into ForeignCo
- ForeignCo incorporates its UK branch into UKCo
- UKCo's foreign subsidiary
- ForeignCo's UK subsidiary
- UKCo: debt financing of foreign subsidiary
- ForeignCo: debt financing of UK subsidiary
- UKCo: equity financing of foreign subsidiary
- ForeignCo: equity financing of UK subsidiary
- UKCo incorporates a foreign holding company
- ForeignCo incorporates UK holding company
- UKCo licenses ForeignCo
- ForeignCo licenses UK subsidiary
- Finance and licensing companies
- ForeignCo repatraites profits to UKCo
- UKCo repatriates profits to ForeignCo
- UKCo acquires foreign business
- ForeignCo acquires UK business
- UKCo acquires and disposes of foreign real estate
- ForeignCo acquires and disposes of UK real estate
- Mergers and reqorgainsiations: UK outbound
- Mergers and reorganisations: UK inbound
- UKCo sells its foreign business
- ForeignCo sells its Uk business
Each step in the cycle is analysed from both the UK and foreign tax viewpoint, with summaries, cross-references and citations to the relevant UK legislation, as well as references to relevant foreign tax rules in 20 of the jurisdictions that are among the UK’s main trading partners.
- Succinct writing style – short paragraphs and uncluttered text
- Illustrated and explained with diagrams, tables, and examples
- Real life case studies
- Practical information on UK and foreign tax issues
- Summarises relevant UK legislation
- Spotlights relevant foreign legislation
- Advice on sensible tax planning techniques
- Ample references to the practical impact of the OECD BEPS project, the EU Anti-Tax Avoidance Directive, the Multilateral Instrument and Tax Treaties
- A roadmap for students
- A practical hands-on guide for everyday work in the office
Available in hard copy, and online with frequent updates.
Allan Cinnamon is a well-known figure in international tax circles who has written and spoken widely on this subject.
He specialised in international tax planning for more than 30 years with BDO where he was the firm’s head of international tax and chairman of the BDO International Tax Committee.
He continued in the role of international tax consultant to the firm, advising clients on all aspects of cross-border planning, appraising new legislation on international issues, creating and running the firm’s and BDO International’s international tax training programmes, and writing articles for professional journals.
Previously visiting teacher at Queen Mary, University of London and The Institute of Advanced Legal Studies he currently teaches and speaks on a wide range of international tax subjects, principally on cross border planning and tax treaties.
He has written a number of books and many articles on international tax planning including a regular series for Tax Journal (Fiscal Odyssey) and Tax Analysts/Tax Notes International (Letter from London), and a quarterly Tax Treaty Briefing for Croner-i.