COURSE OBJECTIVES: The course will concentrate on cross-border planning techniques for outward investment and will therefore consider the UK and host country tax implications involved, including Europe, the USA and the Far East.
At the end of the course participants will be aware of:
- The principal UK and foreign tax rules relating to outward UK investment, including Double Tax Treaties; and EU Treaties, Cases and Directives
- The application of these rules and the principles to transactions resulting from the typical cycle of international business growth
- The consequent planning opportunities and techniques designed to minimise the tax burden in both the UK and foreign jurisdictions
- The need to co-ordinate the UK and foreign tax plan to achieve the above objectives
COURSE CONTENT
- Exporting products and services
- E-commerce
- Licensing and franchising
- Foreign branch or subsidiary?
- Startup losses and 'double dips'
- Financing the branch or subsidiary, including forex implications
- Incorporating the branch
- Holding company locations
- Financing techniques
- Joint ventures
- Acquisitions including post-acquisition restructuring
- Repatriating profits
- Tax treaties and planning
- Disposals
- The impact of ECJ decisions
- Controlled foreign company rules and other anti avoidance hurdles
- The use of offshore jurisdictions
- Hybrids
- Tax arbitrage
- Foreign Dividends & Worldwide Debt Cap
WHO SHOULD ATTEND
The course will be of interest to all finance and tax personnel whose companies are engaged in international expansion out of the UK.
"Useful, practical and comprehensive run through of all the issues for consideration in international structures. A day well spent – thank you."
Would you like this course run in-house? Call us on 0207 566 8207 to find out more