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Practical International Tax Planning for UK Businesses

Practical International Tax Planning for UK Businesses

Author: Allan Cinnamon
Publisher: Croner-i
ISBN: 9781788872263
Published In: February 2019
Format: Hardback (2 volumes)
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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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.

Key features

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

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.