Introduction to International Tax

This course is an introduction to structures underlying international corporate tax planning. The principles are illustrated throughout by examples drawn directly from experience. The course is of general application rather than dealing with the legislation of particular countries. A basic knowledge of UK corporation tax is assumed.

COURSE CONTENT

• The beginnings of international expansion, when a tax presence abroad has to be recognised

• The choice of legal form

  - Branch or subsidiary

  - Entity classification

  - Hybrids

• The use of holding companies in structuring the expansion

• Financing overseas operations:

  - Debt or equity

  - WHT

  - Forex

  - Deductability of interest

• Introduction to transfer pricing, the movements of products, intangibles and services

• Controlled foreign companies legislation

• Anti tax haven legislation

• The remittance of profits

• Corporate residence

• Double tax relief and tax treaties

• IP, intangible assets and goodwill

• The impact of EU case law