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Restructuring your international operations

Understanding upcoming changes to your group, and the tax impact of those changes

International businesses are always evolving. Structural changes are common as you grow: whether that is through a merger, an acquisition, a disposal or an internal re-organisation. We can work with you to understand the tax impact of these changes, such as: is there a chargeable gains impact following a structural change, and are there any reliefs available? Will alterations to your holding company chain impact repatriation strategy and cross border payments?

Changes to your international business may also arise from activity within the structure – for example movements of IP, your people, or where certain functions take place. An international supply chain is a complex machine and a number of international tax issues could be relevant to your business, including:

  • the UK Controlled Foreign Company (CFC) rules
  • the anti-hybrid provisions, diverted profits tax
  • withholding taxes on cross border payments
  • IP licensing and amortisation
  • cross-border reporting requirements.

Partnering with you through business change

We work closely with our clients to understand their wider stakeholder needs. We can help you navigate the complex international tax rules relating to cross border activity and translate that into direct and practical advice.


Dan Hartland

+44 (0)121 232 5161

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