International Corporate Tax Planning 

• How to structure international operations in a tax efficient manner to reduce the group's overall tax rate
• How to deal with different tax systems at various stages of development
• In UK inbound situations, assistance and guidance in dealing with the regulatory requirements that exist in entering the UK, so that the business is able to focus on the commercial aspects
• Incurring a tax charge levied contrary to EU lawFacing a restriction on interest deductions in the UK, especially under the worldwide debt cap rules

Bringing you peace of mind

• We provide a full range of International Corporate Tax services which include advising on all outbound and inbound international tax issues, asset finance, treasury and corporate debt issues, and EU law
• We provide tailor made solutions for a client's particular facts and circumstances
• We advise not just on the corporate tax consequences of any particular transaction, but provide advice in relation to all of the tax and accounting consequences so that our clients have a complete picture of all the issues, risks and benefits arising from any particular solution
• We can also provide assistance with managing interest restrictions under the worldwide debt cap, including a software package for carrying out calculations and reporting

What's in it for you?

• Reducing the effective global tax rate 
• Mitigating tax risk 
• Recovery of overpaid tax
• Meeting regulatory requirements to be compliant in all jurisdictions
• Enabling the client to focus on achieving their commercial objectives

Why KPMG?

We provide a multi disciplinary team - made up of lawyers, accountants and HM Revenue and Customs trained staff which gives us a wide understanding of all areas of international corporate tax

• We have over 750 offices across the globe giving clients access to tax advice across all regions in which they do business

Case Study

• Our multinational client used one set of numbers for both statutory and management reporting
• There was a tension between arm's length pricing needed for statutory accounting purposes and management transactions needed to drive optimal corporate behaviour 
• The trading model being used for statutory purposes was extremely complex with hundreds of legal agreements. Due to this complexity it was hard for any one person to understand the trading model and consequently it was poorly implemented, leading to both direct and indirect tax inefficiencies
• This was not just a tax issue but also a management information issue and so we worked closely with our colleagues in advisory as well as our client to develop a solution which simplified the group's internal trading model and delivered tax savings in the region of £50m+ per annum