International Tax

Global compliance and reporting obligations can be a time consuming and daunting task for any international business. Whether you have recently expanded abroad or are already a well established large multinational group.

Crowe can provide local in-country knowledge and expertise. We understand the challenges you face and can assist you:

• Understand the local in-country reporting requirements – what are the key reporting obligations and what needs to be filed and by when?
• Co-ordinate the tax reporting information required from your centralised shared service centre and local in-country finance team
• Manage your tax accounting and provisioning
• Undertake UK to local GAAP reconciliations
• Complete your local statutory reporting on a timely basis
• Prepare and submit your local corporate income tax returns
• Meet your transfer pricing obligations
• Manage local tax authority enquiries and investigations
• Set up standardised reporting procedures and processes
• Proactively undertake tax planning and appropriately manage you're business's global tax position.

To manage your groups transfer pricing needs. International trade is constantly evolving and local taxing authorities are continuing to look at ways to ensure that multinational enterprises are paying the right amount of tax and that profits are taxed where value is created.

The UK has had a transfer pricing regime for many years, although small and medium enterprises (SMEs) have largely been exempt from the need to consider transfer pricing.

The transfer pricing exemption broadly applies to all SMEs that have fewer than 250 employees and either balance sheet assets of less than €43 million, or turnover of less than €50 million. However, the exemption does not apply to transactions with related parties in territories with which the UK does not have a double taxation treaty with an appropriate non-discrimination article.

From 1 April 2019, this potentially all changed for SMEs in the UK, with the introduction of the anti-profit fragmentation legislation.

For accounting periods beginning on or after 1 April 2023 new transfer pricing legislation came into force for UK-taxable entities which form part of a multinational group whose turnover exceeds €750 million. The legislation requires effected groups to keep transfer pricing documentation in the Master File and Local File formats specified by the OECD regulations. This is purely a change to the format of the records that need to be kept.

Entities which are not large enough to be caught by these rules, but not small enough to receive an exemption from the transfer pricing rules will not be affected by this change. They will still need to keep transfer pricing documentation, but it doesn't need to be in the OECD specified format.

How we can help

In conjunction with our Crowe Global network our team can advise your business on international taxation and transfer pricing matters including:

• advice on transfer pricing policies and documentation
• economic and functional analysis
• master and local file preparation
• benchmarking studies
• advanced pricing agreements (APAs)
• advice on withholding taxes.
• advice on overseas expansion, structure and profit repatriation. See our International Trade services.