Overseas holding companies
Article Abstract:
UK based multinationals must seek to maximize their after-tax profits through careful tax planning. The introduction of controlled foreign companies (CFCs) legislation in 1984 reduced the advantages of using tax havens for subsidiaries of UK multinationals. However, tax advantages can be gained through the use of overseas holding companies (OHC) to control overseas subsidiaries. OHCs can be used to defer UK tax on capital gains and income, average foreign taxes, reduce withholding taxes, and accumulate income and capital gains. The OHC's location will depend on the purpose for which it was established. The tax haven chosen as the location shouldn't tax foreign dividends, should have a large number of double taxation treaties concluded, and should assess a low withholding rate on dividends remitted to the UK.
Publication Name: The Accountant's Magazine
Subject: Business
ISSN: 0001-4761
Year: 1990
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Cross-border joint ventures
Article Abstract:
Tax planning on an international basis has become increasingly important due to: the increasing internationalization of business; the increasing volatility of financial markets; and the effects of tax harmonization. Cross-border joint ventures entail the transfer of existing business to a joint venture vehicle. In unincorporated joint ventures, the partnership profits of UK companies are treated as separate trade profits for computing taxes. In incorporated joint ventures where the vehicle is a UK resident company, the UK parent receives profits by the way of dividends. If the joint venture vehicle is a company, withholding taxes and dividends must be considered in tax planning strategies. The use of a transparent joint venture vehicle may reduce additional withholding tax burdens.
Publication Name: The Accountant's Magazine
Subject: Business
ISSN: 0001-4761
Year: 1990
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Tax angles on the acquisitions and mergers trail
Article Abstract:
As mergers and acquisitions opportunities expand, driven by such factors as tax changes and the approaching 1992 integration date, it is critical to be aware of the recent domestic and international tax issues. Important tax considerations include: target company tax issues; earn-out arrangements; individual shareholder tax issues; and international tax issues.
Publication Name: The Accountant's Magazine
Subject: Business
ISSN: 0001-4761
Year: 1989
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