Tax Partner Paul Smith spoke at a conference on corporate tax on 11 June 2014.
Paul Smith spoke on the subject of “Taxation for International Groups” at a conference organised by IBC Global, held in London.
In his briefing, Paul covered the topics below:
- Location, location, my favourite (tax) locations
- Places to watch – other countries becoming competitive
- IP planning and update on Google/Apple type structures
- Take care with beneficial ownership & substance – tax treaties are important
- Transfer pricing - both a risk and an opportunity
- Interest deductions – avoid thin cap, earnings stripping, debt cap etc.
- Group Finance Companies – will become increasingly important as interest rates rise
- Trade with (and not in) high taxed countries – where practical
- Using partnerships in group structures
- Some unusual benefits of operating through offshore entities
For more information on this topic, please contact Paul Smith