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Course Overview The course will be of interest to all finance and tax personnel whose companies are engaged in international expansion out of the UK and will look in particular at Europe, Australia, Japan and the USA. The course will concentrate on crossborder planning techniques for outward investmentand will therefore consider the UK and host country tax implications involved. The course is intended to follow on from Introduction to International Tax and will therefore assume a basic knowledge of international tax issues. Course Outline - Exporting products and services
- E-commerce
- Licensing and franchising
- Foreign branch or subsidiary?
- Startup losses and 'double dips'
- Financing the branch or subsidiary, including forex implications
- Incorporating the branch
- Holding company locations
- Financing techniques
- Joint ventures
- Acquisitions including post-acquisition restructuring
- Acquiring real estate for business or investment purposes
- Repatriating profits
- Double tax relief
- Tax treaty planning
- Disposals
- The impact of ECJ decisions
- Transfer pricing
- Controlled foreign company rules and other anti avoidance hurdles
- Treasury consents
- The use of offshore jurisdictions
- Hybrids
- Tax avoidance disclosure rules
- Tax arbitrage
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