International Tax Planning
horizontal rule


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


Allan Cinnamon has specialised in international tax planning for more than 35 years in a long career with BDO. Prior to his retirement as a partner, he was the firm’s head of international tax and chairman of the BDO International Tax Committee. He then 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. He teaches, speaks and writes widely on a range of international tax subjects, including the presentation of international tax planning courses at Queen Mary, University of London and The Institute of Advanced Legal Studies. He created the original concept for the CCH International Tax Planning Manual (now CCH Worldwide Business Tax Guide) and was its founding editor. He also created for CCH the concept which later became the I

Fees (ex VAT)


Member Fee
£315.00

Non Member Fee £575.00
Locations & Dates
21/06/2012 - London (09:30 am - 05:00 pm) Speaker & Venue Details BOOK >>