International Tax

The Guidance Notes below cover a broad range of applied knowledge in respect of international tax issues that has been provided to our clients, and updated to reflect the companies’ feedback and practical experience.

  • GNT 11: Transfer Pricing Essentials

    This guidance note sets out an overview of the rationale and the requirements of transfer pricing and the arm’s length principle. It discusses the typical models used in life sciences and touches upon the transfer pricing documentation requirements. (Password required)


  • GNT 12: UK the Case for Inward Investment

    In recent years Government has worked hard in endeavouring to position the UK as having the most competitive tax framework among the G20. This guidance note summarises the key tax benefits of setting up an EMEA regional headquarters in the UK. (Password required)


  • GNT 13: Expansion into New Territories

    As a business expands its international footprint it will be better served by having a framework for establishing a presence in new territories. This Guidance Note includes a high level step plan which can be used for each new entity and which can be developed, in each case, for specific requirements in that jurisdiction. (Password required)


  • GNT 14: Benefits of Incorporating in the UK

    The UK has created a very favourable tax framework for innovative start-ups and spin-outs. In recent years Government has worked hard in endeavouring to position the UK as having the most competitive tax framework among the G20. This guidance note is intended as an initial point of reference to those involved in establishing a new BioScience venture and who are unfamiliar with the UK tax environment and, in particular the range of incentives that are on offer. (Password required)


  • GNT 23: Permanent Establishments

    This guidance note addresses circumstances in which a tax presence might be created in a new territory presenting new taxing rights for authorities. Following recent international initiatives, predominantly the OECD’s BEPS programme, tax authorities are now better equipped to identify permanent establishments and assess tax on local activities. (Password required)


  • GNT 24: Intercompany Agreements for Transfer Pricing

    This Guidance Notes explains best practice for drafting and maintaining intercompany agreement for transfer pricing purposes. It also includes links to template agreements for common transactions in Life Sciences. (Password required)


  • GNT 26: BEPS Overview

    This Guidance Note is intended to be an introduction into the Base Erosion and Profit Shifting (“BEPS”), particularly, into how the OECD BEPS initiatives are most likely to impact Life Science companies in the UK. Rather than providing an overview of all 15 actions, this Note focusses on Actions 7, 8-10 and 13. (Password required)


  • GNT 32: Setting up in the US

    For many UK headquartered companies their first step in international growth is to establish a presence in the US for early stage commercial purposes, occasionally to expand R&D or simply to have personnel who can be closer to US investors, capital markets and opinion leaders. This Guidance summarises the main tax considerations in doing this. (Password required)


  • GNT 33: Diverted Profits Tax

    The Diverted Profits Tax (“DPT”) came into force on 1 April 2015 to deter ‘contrived’ arrangements used by multinationals that divert profits from the UK and result in erosion of the UK tax base. It is charged at a rate of 25% on a company’s profits deemed to have been diverted from the UK. This Guidance Note sets out the key implications. (Password required)


  • GNT 35: Tax Implications of Brexit on the Pharmaceutical Industry

    This Guidance Note outlines some key tax implications of Brexit on the pharmaceutical industry. The implications for the future framework for Customs Duty will be of upmost significance but the impact on VAT and, to some extent, Corporation Tax will also be of importance. This Note does not cover every aspect of UK and international taxation that could be affected but draws out those considered to be of greatest significance for the Life Sciences sector. (Password required)


  • GNT 43: Tax Residence

    This note is intended to be an introduction to the tax residence rules for companies.  Corporate tax residence is an important aspect, mostly because it determines the jurisdiction which has the right to tax the company’s profits.  This is particularly important to groups who are expanding into new territories. (Password required)


  • GNT 51: Double Tax Treaties

    Double tax treaties (“DTTs”) are international agreements, concluded between two (bilateral) or multiple (multilateral) countries, primarily to deal with cases of double taxation. DTTs also serve as the legal basis for cooperation between the contracting states to prevent tax evasion, and often contain clauses denying treaty benefits in tax avoidance situations. This Guidance Note discusses double tax treaties and provides a summary guidance on their application. (Password required)


  • GNT 52: PFICs

    Passive Foreign Investment Company (“PFIC”) rules aim to prevent the deferral of income in a non-US corporation from the US income tax net, by denying the US persons the benefit of deferral of US taxation on all passive investments channelled through non-US corporations. These rules affect a wide range of US shareholders and foreign corporations and achieve this end by: (1) directly taxing US investors in PFICs and (2) by indirectly imposing an interest charge on the deferred distributions and gains of these investors. This Guidance Note outlines the definition of a PFIC, the tax implications of holding PFIC stock and the elections available to shareholders under the PFIC rules. (Password required)


  • GNT 53: Implementation of BEPS

    Although the OECD’s Base Erosion and Profit Shifting (“BEPS”) recommendations are merely advisory, governments of many countries, including the UK, have confirmed that they will be implementing some or most of the recommendations. This Guidance Note provides a look into how the BEPS actions are being implemented in the UK. (Password required)


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