International tax

New Pillar 2 rules will fundamentally change the international tax landscape and we have developed a five-stage process to support you throughout your Pillar 2 journey. Whether you are right at the beginning or have started to look at how the new rules may impact your group, we can tailor our approach to fit your needs.  

This may be an initial move overseas or a more fundamental restructure of international operations. We guide you through the complexities that come with working cross-border in a digital age from a direct and international tax perspective, as well as various reporting requirements and changes in tax base introduced post-BEPS (base erosion and profit shifting).

Understanding group structures and intragroup transactions – and how these could be caught under the anti-hybrid mismatch regulations.
 

Identifying and managing potential residency risks to ensure your business is compliant with relevant reporting obligations and managing ‘exit charge’ risks.

Identifying where companies could be creating a taxable presence outside the territory of company residence - permanent establishments - and ensuring any local tax requirements are met, including appropriate allocation of profits to the permanent establishment. Ensuring groups are compliant with the controlled foreign company (CFC) regulations, any appropriate disclosures are made in company tax returns and CFC charges are paid where applicable.

Reviewing cross-border transactions and profit repatriation policies to identify and manage any withholding tax risks. Also, analysing treaty positions and where applicable that the appropriate tax is withheld.

Helping in the design, development, documentation and defending transfer pricing policies for your business. Find out more on transfer pricing.
 

Ensuring your business is able to move people cross-border, capitalising on opportunities, while managing the associated costs and risks. Read more about our global mobility services.

Ensuring your business can effectively navigate the complex system of global indirect tax rules. Find out more on how we can help you with indirect tax.

Supporting employers, international corporate trustees and executives on the cross-border taxation of company reward structures (shares plans, LTIPs, Employee Benefit Trusts, retirement and company benefit plans) including the establishment, deductibility and taxation of such plans.