International Tax Planning

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International Tax Planning

With each country in the world managing their own national tax systems and a myriad of international tax treaties and supranational regulatory systems that affect the taxation of individuals, structures (including companies) and transactions tax planning is an extremely complicated area.

We work with a number of client's assisting with their planning requirements and whilst we cannot provide specialist tax advice we consider that it is better to introduce our prospective clients international tax experts (where they do not already have access to a tax professional) to ensure that they get the most appropriate advice for their particular requirements.

As a guide, whilst it is always necessary to look at the specific tax laws that apply in each country that can affect the taxation of an event (e.g. migration), transaction (e.g. import/export) or entity (e.g. individual, company, trust, etc..,.), many Governments have to a differing extent accepted certain general principles contained in the OECD model tax convention and this helps when considering the fundamental issues need to be considered before starting to look at the specific tax laws of a country. For further information on some of the general OECD principles that affect taxation of companies see our International Trading section.

For example where the convention refers to entities that have a “permanent establishment” in a country as being a factor to a company being tax resident there many OECD member countries have now adopted the same concept into their national legislation. This has allowed tax and cross border experts to be able to plan a route through international tax issues by recognised international principles. The OECD model convention and various laws and treaties attempt to regulate who is taxable, where and by which country, providing mechanisms to avoid (in some cases) double taxation and to dissuade abuse, evasion and to an extent tax avoidance.

Specialist tax advisors can assist in identifying how best to structure a transaction or a business relationship to ensure the tax efficient route to take within the laws, regulations and treaties. As mentioned as this is such a complex area HL Fiduciaries Limited does not provide specialist tax advice but we work with a number of international tax experts who are able to assist our clients with their individual specialist requirements. After an initial discussion to understand your requirements we would be happy to assist in introducing you to a relevant tax specialist and working with them to establish the most appropriate solution for your requirements.