Compliance is key to any organisation


Whether you are establishing new operations overseas or looking to maintain current activities.

Our team of dedicated tax and transactions experts can help identify and mitigate areas of change that affect your company.

Consider how the new UK-EU trade deal might impact your approach to...

  • Consider how the new UK-EU trade deal might impact your approach to...

    Withholding taxes

    The payment of dividends, interest or royalties between the EU and the UK may now carry a withholding tax burden. This could be a real cost where the applicable treaty rate is not zero, and the tax is not available for credit against the relevant UK or EU taxes.  

  • Consider how the new UK-EU trade deal might impact your approach to...

    Group structures

    UK companies may now break EU tax grouping relationships or consolidations. This may lead to possible clawback of previously claimed reliefs, and an inability to claim reliefs in the future.

  • Consider how the new UK-EU trade deal might impact your approach to...

    Corporate taxes

    The new agreement results in limited direct changes to corporate and direct taxation, but there some specific changes to consider the impact of, including:

     - Changes to the UK’s implementation of the EU’s “DAC 6” Mandatory Disclosure rules and a move towards replacing these with the OECD’s Mandatory Disclosure Rules.

    - The UK and EU have agreed to continue their support for the OECD BEPS initiative, so we should expect the UK to continue to implement changes proposed by the OECD.

    - The agreement now ends the EU State Aid regime in Great Britain, subject to certain conditions in the agreement, offering the UK more flexibility in setting future tax legislation looking forwards.

  • Consider how the new UK-EU trade deal might impact your approach to...

    Transfer pricing and exit charges

    Reorganisations to internal supply chain, financing flows, incorporation of new entities for regulatory, customs or other commercial reasons may change the location of significant people functions, risks and assets. If value has moved or will move out of the UK there is a risk of an immediate and potentially significant corporate tax charge.

  • Consider how the new UK-EU trade deal might impact your approach to...

    Foreign exchange

    As the full impacts of the deal on the economy and sterling work through, businesses should consider whether their tax teams are fully aware of positions treasury teams are taking and that UK corporation tax risks are being managed accordingly.

Things you need to consider going forwards

  • Things you need to consider going forwards

    Review your tax position

    You can assess the group structure to gauge the withholding tax position and identify any claims or further work required. At the same time, review group structures and tax consolidations for potential impact. Groups should also consider the impact of any recent or future reorganisations in response to Brexit. 

    Prepare a value chain analysis and review the below factors with a view to understanding the potential transfer pricing implications:

    • – activities to ensure compliance
    • locations of key people functions
    • – intangibles for new location of development, enhancement, maintenance, protection and exploitation.
  • Things you need to consider going forwards

    Explore deal prospects

    The new UK-EU relationship may create opportunities for those wishing to enter or exit new markets.

Our work with clients

Over the last three years we’ve worked with organisations of many sizes and sectors to help them prepare for political volatility.

Establishing a regulatory presence in Europe

Regulatory risk resulted in a Fin-Tech organisation needing to establish a presence in Europe. We worked alongside national regulators to establish what substance requirements were required as part of a continuity planning exercise. Once agreed our teams (across transfer pricing, VAT and corporate tax) supported the implementation ensuring a smooth transition for the client and their customers.

There's no one size fits all approach to Brexit. Speak to one of our experts for a response tailored to you.

Not found what you are looking for? Discover our other priority areas.

Imports and exports

Are you ready for the changes?

Read more Imports and exports

People and skills

Will your people be affected?

Read more People and skills

Cost and cashflow

Have you planned for the impact?

Read more Cost and cashflow

Navigating Brexit

Practical steps for business leaders

Read more Navigating Brexit