International tax

Whether your company is expanding into new markets, planning to acquire an overseas business or starting a new business in the UK, you need to manage cross-border tax issues carefully. Our dedicated international tax professionals can support you with a range of services for inbound and outbound businesses.

With the global trend toward greater tax transparency, tax is attracting growing attention from governments, the press and the public. Tax authorities around the world have allocated increasing resources to investigate and monitor business activity across international borders, particularly in relation to corporate structures, profit attribution, tax avoidance and transfer pricing.

Nexia

As part of Nexia International, the ninth largest global network of financial services firms, Smith & Williamson provides a truly international service. We offer access to a multinational network of tax experts, providing global reach and local knowledge wherever you choose to do business.

We have a broad knowledge and understanding of the challenges and pressures you face in protecting and growing your business and wealth. With capabilities in over 120 countries, we work closely with our Nexia colleagues to provide joined-up solutions to help our clients achieve their financial ambitions, no matter where they are based or active. In particular, we assist many US inbound and outbound businesses and work extensively with our US teams.

Our services

If your business operates in multiple jurisdictions, complying with local tax laws and staying on top of changing legislation requires diligence and considerable time and effort. From corporate tax compliance and reporting, to maximising cross-border tax efficiency or advising on corporate structures and treaty qualification, our experts can alleviate your tax burden, enabling you to focus on growing your business.

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Transfer pricing

When operating on a global basis, it is vital to ensure that your business has undertaken the required analysis to ensure compliance with transfer pricing legislation in each jurisdiction, and to accurately reflect the value attributable to each territory in which it operates.

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International Capabilities

Inbound businesses

The UK offers unparalleled opportunities for businesses to access new markets and expand internationally. It is uniquely placed, with strong US and European connections and mature, flexible markets. London boasts the world's largest financial centre, and companies benefit from low corporation tax rates, a highly skilled workforce, and a flourishing entrepreneurial climate. See how your business might take advantage of the opportunities for expansion to the UK.

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Outbound businesses

Globalisation has led to an ever-increasing need for businesses to operate across the world. In the era of online business, such expansions can be done quickly and seamlessly and, with our Nexia network, Smith & Williamson is well placed to help explore expansion opportunities for your business, to ensure that you hit the ground running and to help you avoid any unexpected complications.

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Country-by-Country Reporting

Large multinationals with consolidated annual turnover in excess of €750m, or the equivalent if they were required to consolidate, are within the scope of the Country-by-Country Reporting rules and will need to prepare a full Country-by-Country Report for submission to HMRC each year.

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Frequently asked questions

Is Smith & Williamson an international firm?

As part of Nexia International, the ninth largest international network of independent accounting and consulting, Smith & Williamson offers a truly international service.

With over 700 offices globally, covering more than 120 countries, the Nexia network provides Smith & Williamson with the platform to deal with all your international demands. Nexia is built along the same principles as the service provided by Smith & Williamson, providing a personal, partner-led approach.

While Smith & Williamson works closely with the network as appropriate, our International Tax team also has the experience to deal directly with the majority of your international tax questions.

Visit our Nexia site here.

How can we obtain Double taxation relief?

UK companies incurring foreign tax can generally claim Double taxation relief where they have taken all reasonable steps to minimise the foreign tax. Overseas companies can usually apply for relief from UK withholding tax where they are resident in a jurisdiction that has a double tax treaty with the UK.

Incurring foreign tax can have an adverse impact on cashflow and increase a company’s effective tax rate. UK resident companies are taxed on their worldwide income and those with overseas operations or foreign source income may incur tax in overseas tax jurisdictions.

UK tax relief in respect of foreign tax incurred can usually be claimed under the terms of a double tax treaty (DTT) or, where there is no treaty in place, by unilateral relief. The outcomes of both are very similar.

Double taxation relief (DTT)is only available when all reasonable steps have been taken to minimise the foreign tax incurred, by making any relevant elections or claims for relief in the territory in which the tax is imposed.

A company may be able to apply for relief from UK withholding tax if it is resident in a DTT country and receives UK-sourced income. The relief is dependent on the terms of the relevant DTT and is not automatic. Foreign taxes can often be reduced under a DTT.

In order to apply for relief, either for relief at source or repayment of UK withholding tax already made, overseas companies must apply to HMRC by submitting a form certifying the tax residence of the company. HMRC also operates the DTT Passport Scheme, whereby overseas lenders can apply for a Treaty Passport that permits payments on loans under the scheme to be paid without the deduction of UK withholding tax.

Only lenders registered in countries that have a UK DTT may be recognised as part of the scheme. To register, an application must be made to HMRC.

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Alistair Shaw

Partner, Corporation Tax, Business Tax

Business tax
London

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