International Tax Planning – Part 2

Speaker:  Allan Cinnamon  |  CPD Hours: 6.0

Price £575 plus VAT

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This course will concentrate on cross-border planning techniques for outward investment and will consider the UK and host country tax implications involved, including Europe, the USA and the Far East. The implications of BEPS and the EU Anti Avoidance Tax Directive on existing and upcoming cross-border structures will be considered, including the extent to which these recommendations and directives have been, and are likely to be, implemented into UK and foreign tax legislation.


Recap of UK fundamentals including residence, effective management, CFC, EU law and tax treaties

Practical planning

  • Doing business abroad without incurring foreign tax
  • Foreign permanent establishment?
  • Exporting products and services
  • The digital economy
  • Licensing and franchising
  • Foreign branch exemption
  • Start-up losses
  • Incorporation
  • Financing
  • Profit shifting
  • Holding, trading, financing and licensing companies
  • Corporate partnerships and joint ventures
  • Acquisitions including post-acquisition restructuring
  • Mergers and reorganisations
  • Business Restructuring
  • Repatriating profits
  • Disposals


The course will be of interest to all tax advisers whose companies and clients are engaged in international expansion out of the UK legislation.

A knowledge of the basic elements of international tax planning is assumed – our International Tax Planning – Part 1 may be useful if you need to attend an introductory level course.

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