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International Tax Planning Part 1

International tax planning is an essential discipline for UK groups operating internationally. This is especially current in the light of recent UK reforms such as the CFC rules, the Foreign Branch Exemption, the Patent Box, revisions to the Exit Tax rules for companies and the General Anti-Avoidance rules. Coupled with this is the OECD project on Base Erosion and Profit Shifting which heralds the start of a new era in international co-operation on anti-avoidance.

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Learning Objectives

The course serves as an introduction to international tax planning for tax advisers and finance personnel who are looking for an understanding of how international tax planning has an important role to play in the structuring of a UK group’s foreign operations and how the new BEPS climate will impact on existing and upcoming cross-border structures. The course will be primarily based on a real life case study.

At the end of the course participants will be aware of the principal UK and foreign tax rules relating to outbound investment and the application of these rules. The course will also cover the consequent planning opportunities, the current and anticipated anti-avoidance rules and the need to co-ordinate the UK and foreign tax plan.

Course Content

Building blocks

  • Corporate residence
  • CFC reform
  • Foreign Branch exemption
  • The UK Patent Box
  • The use of treaties in international tax planning
  • The impact of EU law and how this may be affected by Brexit
  • Some special features in foreign jurisdictions
  • Anti-avoidance rules including BEPS and the EU Anti Tax Avoidance Directive

Practical planning through a case study of a domestic group expanding abroad

The case study will analyse the UK and foreign tax consequences that arise through the typical international expansion of a UK business that develops by stages into an international group. The impact of BEPS and the EU Tax Avoidance Directive on the structuring possibilities will be factored into the case study.

WHO SHOULD ATTEND

The course will be of interest to tax advisers and finance and audit personnel seeking an introduction to international tax planning. No previous knowledge of international tax planning is required.

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