International Tax

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.