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International Tax

Our international tax team has considerable experience in advising corporate and financial institutions combining comprehensive tax structuring with quality advisory skills.

We advise non-UK clients on taxation issues relating to their UK activities and interests and UK clients on their non-UK interests. This includes advice to multinationals and high net worth non-domiciliaries. We also co-ordinate advice for cross-border transactions which involve a number of jurisdictions.

We can help you with:

  • UK tax aspects of multi-jurisdictional structures
  • Establishing a business in the UK through a branch, subsidiary or agent 
  • UK tax and regulatory issues on extending equity participation to UK-based (and non-UK) employees
  • Advice to expatriates on UK taxation
  • Advising UK persons on structuring investment and partnering outside the UK 
  • Cross-border financing and royalty agreements
  • Advice to non-domiciliaries on issues relating to UK investment and tax status
  • Structuring non-UK acquisitions and investment into UK groups. 

Recent experience:

  • Advising Middle Eastern government on cross-border tax exposures relevant to its strategic capital development fund structuring.
  • Advising AngloAmerican plc on the tax provisions in a package of framework and precedent (FIDIC based) Engineering, Procurement and Construction Management (EPCM) and construction contracts for their international mining operations and project worldwide.
  • Structuring a £230 million renewable energy cross-border corporate investment platform, involving UK, Luxembourg, Spanish, French and Jersey law.
  • Advising Spanish corporate setting up a UK business via a UK LLP above an operating company and LLP.
  • Advice on the repatriation of profits to the UK from the Dubai branch and subsidiary of a UK corporate on the establishment of its Dubai business.
  • Advising US insurance and financial services group on the tax led restructuring of UK interests and eventual disposal of UK activities crystallising substantive US tax losses.
  • Advising UK group on structuring overseas investment in its underlying non-UK ventures.