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Expatriate & International tax planning

Whether you are a small business looking to expand overseas, or a multinational group seeking to reduce their taxes, Hillier Hopkins can assist in providing the best solution through international tax planning.

International tax planning can enable you to:

• Avoid double taxation
• Reduce the overall rate of taxation
• Claim local tax benefits
• Take advantage of gaps in local legislation

Our expertise includes:

• Transfer pricing
• Foreign investors investing in UK property
• Forming a branch/subsidiary overseas
• Controlled foreign companies
• UK Non-Resident companies
• Using double taxation treaties

The transfer-pricing document generally analyses the arms length nature of related party transactions between a UK company and its foreign affiliates for a particular tax year. As advised during our meeting the corporation tax self-assessment return when submitted to the Revenue needs to comply with the transfer pricing legislation.

The legislation is designed to ensure that there is no tax leakage from the UK and the object of the document is to show that there is no difference between transactions with related foreign affiliates and prices charged at arms length.

Having a transfer-pricing document, even if the Inland Revenue disagree with the results, will prevent penalties (up to 100% of the tax) being charged. Any transfer prising document would include a Business Description, Functional Analysis and Transfer Pricing Analysis. An alternatively methodology is to go back further to analyse why the company is in business and what rates of return would have been required by the shareholders and compare how this matches up to reality. In terms of convincing results this is less effective than the third party comparisons.