WTP's Private Company International Tax Services (“PCITS”) focuses on the unique cross-border tax issues encountered by privately held companies. Private companies face cross-border structuring, foreign tax credit, tax treaty, and withholding tax issues. Our PCITS professionals have knowledge and experience addressing these issues.
International Structuring
Companies should plan their international business structures to minimize global tax expense. Rules exist to assist companies in managing their global tax expense; however the rules are complex and challenging.
WTP Advisors provides services related to:
Planning tax efficient global structures
Establishing holding company structures
Controlled Foreign Companies planning
Planning for cross border sales and mergers and acquisitions
WTP Advisors recognizes that business goals drive tax planning and use a forward thinking approach to achieve clients’ international tax planning goals.
Foreign Tax Credit Utilization
The foreign tax credit (“FTC”) generally eliminates double taxation on foreign earnings that are repatriated and is intended to enhance the global competitiveness of U.K. companies. WTP Advisors can help U.K. companies maximize their use of FTCs and lower tax expense by implementing FTC strategies and solutions designed to maximize the use of FTCs including:
Expense apportionment
Headquarters expense apportionment
Foreign source income maximization
Foreign title passage planning
Foreign tax pool studies
Repatriation Planning
Multinationals doing business outside the U.K. usually intend to bring part or all of their foreign earnings back home. However, in certain situations Companies may wish to defer UK. tax on those earnings, by keeping those earnings invested abroad until sometime in the future. WTP Advisors’ tax professionals have experience in working closely with clients to design tax effective global cash management strategies that integrate with their business strategies.
Transfer Pricing
Transfer pricing is a term used to describe all aspects of intercompany pricing arrangements between related business entities. Transactions subjected to transfer pricing scrutiny may include transfers of tangible goods, providing intercompany services, transfers of intellectual property, and financing transactions. Transfer pricing affects a multinational company’s tax planning and its financial statements. Transfer pricing has a high profile with both HMRC and foreign tax authorities as more countries pass transfer pricing legislation.
WTP Advisors and its global network of transfer pricing partners offers the following transfer pricing services:
Developing economic comparables to support intercompany pricing and interest rates
Preparing functional analyses
Developing global transfer pricing policies
Planning cost sharing arrangements for joint U.K. and foreign research and development of intellectual property
Preparing transfer pricing documentation
Applying for Advance Pricing Agreements
Inbound Tax Planning
U.K. international tax rules also affect foreign corporations doing business in the U.K. WTP Advisors assists foreign clients with their U.K.corporate tax exposure, focusing on:
Inbound structuring
U.K. trade or business risk
Branch profits tax
Withholding taxes
Conduit financing
Earnings stripping
Tax treaty implications
Contact us to enquire about Private Company International Tax services.
