Interaction with International Taxes - Awareness for the General Practitioner

This course will cover various issues that practitioners should take in to account when dealing with international taxes for business.

In particular, content will include:

• Setting up foreign subsidiaries in the EU post-Brexit
• Management and control test
• UK filing for UK branches of foreign entitie
• Status of tax havens/low tax country and Controlled Foreign Companies (CFCs)
• Double tax treaties
• International tax avoidance counter measures
• Taxation of cross-border transactions – trading in and trading with foreign country
• VAT considerations
• Treatment of foreign tax credits
• Transfer pricing considerations
• Extraction of funds from foreign subsidiaries likely consideration
• Tax residency of foreign subsidiaries and whether dual resident
• Funding of overseas subsidiaries – share capital or loan
• Thin capitalisation today
• Foreign legal considerations
• Differing accounting treatments between UK and non UK entities
• UK Revenue authorities and sharing data with foreign tax jurisdictions