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International Tax Strategies

Double tax in EU and USA (PDF) 34 pages

International Tax Strategies for Entrepreneurs

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Published:December 2010
Edition:3rd edition
ISBN:900 1 80000 200 0
Author:Salvador Trinxet Llorca

The book examines the potential of the UK company as an offshore vehicle for use by offshore trust companies, entrepreneurs, finance directors and their lawyers and accountants. It also assesses the international tax planning opportunities of the new foreign dividend exemption introduced in July 2009 which further consolidate the UK’s standing as one of the most tax-efficient corporate domiciles.

In addition the book examines the substantial shareholder exemption introduced for capital gains (first introduced in 2002) as well as the tax benefits of the UK company as an international trading company and as a recipient of various kinds of non-UK source revenue. It also explains the relevant EU and UK legislation, the operation of double tax treaties, and case study examples illustrating offshore tax planning possibilities using UK companies. Also includes:

Foreign withholding taxes
The new taxation exemption for foreign dividends with reference to the new inclusion of capital dividends
Company residence, including reference to the 2010 UK Court of Appeal case of Smallwood
UK withholding tax and UK dividends, royalties and interest payments
Tax exemption for capital gains
Anti-avoidance, including reference to the UK Thin Capitalisation GLO
Other uses of UK companies, LLPs and Limited Partnerships in international
tax planning
UK trusts and trustees
UK company formation and administration with updates arising from the UK Companies Act 2006
Appendices include full text of the foreign dividend and substantial shareholder exemptions.

International Tax Planning Using UK Companies is essential reading for corporate and tax lawyers and accountants in the UK and overseas, finance directors of large UK overseas companies, and offshore trust companies.

This international tax guide is written for the practitioner seeking a basic guide on the taxation of international transactions. The book is essential for advising individuals and businesses on international tax matters and describes the cross-border taxation of both inward and outward investments. Special sections focus on tax compliance and treaty issues.

Summary of Contents:

•Foreign Earned Income Exemption
•Withholding Tax at Source
•Overview of Treaty Provisions
•Foreign Tax Credit
•Foreign Investment in Real Property Tax