International Tax
Crowe UK’s International tax team is part of a network of professionals who can provide cross-border tax advice to your business through our international network, Crowe Global.
Crowe Global is one on the top 10 accounting networks in the world and with our global footprint we have the capability to deal with any local tax matters that may arise.
We can help you:
- Understand the tax implications of trading overseas.
- Plan your international expansion overseas ensuring it is structured in a tax efficient manner.
- Understand what will lead to the creation of a local country permanent establishment.
- Consider the pros and cons of establishing a branch or subsidiary.
- Navigate the local in country tax compliance registration rules and requirements.
- Understand the withholding tax implications of dividend, interest and royalty payments.
- Manage your ongoing global corporate income tax compliance obligations in local countries.
- Optimise profit repatriation, tax reliefs and allowances.
- Negotiate with HMRC, or other local tax authorities, on difficult and important business matters and handle tax authority enquiries and investigations on your behalf.
- Restructure and reorganise your existing overseas business or group.
- Understand the tax implications of a cross-border acquisition, disposal, merger or demerger.
- Navigate the tax aspects of your cross-border corporate acquisition and disposal transactions.
- Manage your wider international tax areas such as: VAT and customs duty, global mobility and international trade.
Managing your 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
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.
This approach has been enhanced further by the OECD’s Base Erosion and Profit Shifting (BEPS) action plan to how taxing authorities assess transfer pricing.
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.
How we can help
In conjunction with our Crowe Global network our team can advise your business on international taxation and transfer pricing.
- advice on transfer pricing policies and documentation
- master and local file preparation
- benchmarking studies
- advice on withholding taxes
- advanced pricing agreements.
- advice on overseas expansion, structure and profit repatriation. See our International Trade services.
Crowe Global is one of the leading global accounting networks with over 200 independent accounting and advisory firms in more than 145 countries. For almost 100 years, Crowe has made smart decisions for multinational clients working across borders. Our leaders work with governments, regulatory bodies and industry groups to shape the future of the profession worldwide and provide lasting value to clients undertaking international projects.
